The Senior Managers and Certification Regime (SM&CR) is the FCA and PRA’s framework for personal accountability in UK regulated firms. It replaced the Approved Persons Regime and applies to virtually all FCA-regulated firms. The regime has three elements: the Senior Managers Regime (which requires FCA/PRA approval for individuals in the most senior functions and attaches Statements of Responsibility to each); the Certification Regime (which requires firms to certify annually that individuals in certain significant-harm functions are fit and proper); and the Conduct Rules (which set minimum standards of behaviour for nearly everyone in a regulated firm).
Why SM&CR matters
SM&CR shifts accountability from the firm to named individuals. A senior manager who fails to take reasonable steps to prevent a breach in their area can be held personally liable. The Conduct Rules apply to all Conduct Rules staff, not just senior people, and breaches can result in FCA disciplinary action against individuals.
The FCA has signalled ongoing simplification work to the regime during 2026, but the core principle is expected to endure: individual accountability backed by clear Statements of Responsibility and a fitness-and-propriety assessment.
Who it applies to
All FCA-regulated firms and their employees, with different requirements by tier. Banks and large investment firms (enhanced and core firms) have the broadest scope; limited-scope firms have reduced obligations.
Related terms
Conduct risk, Consumer Duty and SYSC.