Senior Managers & Certification Regime (SM&CR)
SM&CR training for UK firms covering individual accountability, the Conduct Rules and reasonable steps — helping staff meet FCA and PRA expectations.
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Request a demoWhat is SM&CR and why does it matter?
The Senior Managers & Certification Regime (SM&CR) places personal accountability at the heart of UK financial services regulation. Introduced by the FCA and the PRA, it replaced a firm-focused approach with one that holds individuals to account for their own conduct and the areas they run. It rests on three pillars: the Senior Managers Regime, the Certification Regime and the Conduct Rules.
Why is SM&CR personally enforceable?
Accountability under SM&CR is personal and enforceable. Senior Managers carry Statements of Responsibility and must take reasonable steps to prevent things going wrong on their watch. Certified staff must be assessed as fit and proper. Everyone subject to the Conduct Rules must meet clear standards of behaviour. When expectations are missed, the regulator can act against the individual, not just the firm.
What does SM&CR training cover?
This course explains how the regime fits together and what it means day to day. Your team will understand the purpose and structure of SM&CR, tell apart Senior Managers, Certification and Conduct Rules staff, and apply the Conduct Rules to real decisions. They will also grasp what reasonable steps and individual accountability mean in practice, through concise, scenario-based content.
What does the FCA expect from SM&CR training?
The FCA expects firms to train Conduct Rules staff so they genuinely understand how the regime applies to their role, not merely to log attendance. It looks for scenario-based content that builds judgement, tailored by tier, with records of completion and assessment. We keep tailored modules for Senior Managers and certified staff current with FCA and PRA expectations.
This course is for everyone in a firm subject to SM&CR, with deeper content for those carrying senior or certified responsibilities.
What your team will learn
- Explain the purpose and structure of SM&CR
- Explain the difference between Senior Managers, Certification and Conduct Rules staff
- Apply the Conduct Rules to day-to-day decisions
- Explain reasonable steps and individual accountability
What's included
- ~25 min of focused, scenario-based learning
- CPD accredited (CII)
- Built-in quiz with a configurable pass mark
- Reviewed and kept current with UK regulation
- Time-stamped completion records for your audit trail
How it works
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Assign it in seconds
Enrol a team, a role or your whole firm from the CityREPORTS dashboard, with automated reminders that chase completion for you.
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Your team completes it
Learners work through the course at their own pace on any device, finishing with a short assessment that demonstrates understanding.
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Evidence it to the regulator
Every completion is time-stamped and retained, so you can prove the right people did the right training at any moment.
Frequently asked questions
- What is SM&CR training?
- SM&CR training helps staff in UK regulated firms understand and meet their obligations under the Senior Managers and Certification Regime. Introduced by the FCA and PRA, the regime holds individuals personally accountable for their conduct and the areas they run. Training must build genuine understanding, not just record attendance.
- Who needs SM&CR training?
- Almost everyone in an FCA-regulated firm, because the Conduct Rules apply to all staff except those in purely ancillary roles. Training should be tailored by tier: Senior Managers need depth on their Statements of Responsibility, Certified Persons on fitness and propriety, and all staff on the Individual Conduct Rules.
- How often must firms provide SM&CR training?
- The FCA expects firms to train Conduct Rules staff when the rules first apply to them and to keep training current as expectations evolve. Annual refreshers are the industry norm. Training should also be updated after new FCA guidance, a change of role, or a conduct finding in the firm.
- What should SM&CR training cover?
- The five Individual Conduct Rules and how they apply to each role, the Senior Manager Conduct Rules for SMF holders, fitness and propriety for Certified Persons, and what personal accountability and reasonable steps mean in practice. The FCA expects scenario-based content that builds judgement, with records of completion and assessment.
- What are 'reasonable steps' under SM&CR?
- Reasonable steps is the standard a Senior Manager must meet to discharge their responsibilities and avoid personal liability under the Senior Manager Conduct Rules. It means taking the actions a reasonable person in that role would take to prevent regulatory breaches in their area, evidenced through governance, delegation, oversight and clear records.
- What records must firms keep to evidence SM&CR compliance?
- Firms must keep Statements of Responsibility and a management responsibilities map for Senior Managers, annual fitness-and-propriety assessments and certificates for Certified Persons, regulatory references for new hires, and training and Conduct Rules breach records. These support certification, the FCA's supervision, and the firm's ability to demonstrate accountability.
- How does SM&CR training relate to the Conduct Rules?
- The Conduct Rules are one of the three pillars of SM&CR. Firms must ensure all Conduct Rules staff understand how the rules apply to their specific role, which is a core training obligation under the regime. SM&CR training therefore typically embeds Conduct Rules content alongside accountability and fitness-and-propriety material.
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