A Statement of Responsibilities (SoR) is a document each Senior Manager must hold under SM&CR, setting out the Senior Management Functions (SMFs) they perform and the Prescribed Responsibilities (PRs) allocated to them. It is the mechanism through which SM&CR creates clear, auditable individual accountability: the FCA and the firm can identify precisely which individuals are responsible for which areas of the business.
What an SoR covers
An SoR must identify:
- The SMF(s) the individual holds (e.g. SMF1 Chief Executive, SMF16 Compliance Oversight, SMF17 MLRO)
- The Prescribed Responsibilities allocated to that individual
- The areas of the business for which they are personally accountable
The SoR is the document against which the FCA assesses whether a Senior Manager took reasonable steps to prevent a breach in their area. If a compliance failure occurs in an area of the business not covered by the Senior Manager’s SoR, the accountability question becomes more complex. Accurate, up-to-date SoRs are therefore the central accountability document of SM&CR, not an administrative formality.
PS26/6 changes from April 2026
FCA Policy Statement PS26/6 made two changes relevant to SoRs:
Flexible PR allocation. PRs can now be split among multiple SMFs, and firms can make allocations beyond the standard examples set out in the rules, provided clear rationale is documented. This allows firms to structure accountability more precisely where a standard PR does not fit neatly with one individual.
Batching of SoR/MRM submissions. Solo and dual-regulated firms may now batch submissions of updated SoRs and Management Responsibility Maps every six months, rather than submitting each change individually. Internal records must still be updated immediately whenever responsibilities change; the batching permission covers FCA submission, not internal governance.
For the full picture of PS26/6’s SM&CR changes, see our guide to SM&CR reform 2026.
Management Responsibility Map
Larger firms (Enhanced SM&CR firms and dual-regulated firms) must also maintain a Management Responsibility Map (MRM), a firm-level document showing how the overall business is governed, how SMFs relate to each other, and how Prescribed Responsibilities are allocated across the Senior Manager population. The MRM sits alongside individual SoRs and must be consistent with them.