FCA Policy Statement PS26/6 brings SM&CR Phase 1 reforms in three tranches: April 2026 (already in force), 10 July 2026, and 1 September 2026. Each tranche has training implications, from updating how you onboard SMF candidates, to revising your certified population, to reflecting new COCON obligations. This guide explains what firms must do and when.
The SM&CR has been the FCA’s framework for individual accountability since it replaced the Approved Persons Regime: for banks from 2016, and for all FCA solo-regulated firms from December 2019. PS26/6 is the output of the FCA’s review of the regime, initiated in 2023 as part of the government’s Edinburgh Reforms and the FCA’s own competitiveness agenda. The changes are Phase 1 only: targeted simplifications that reduce administrative friction without altering the accountability structure.
The FCA’s position is explicit: PS26/6 simplifies processes, it does not weaken accountability. Senior Managers retain personal responsibility for their areas; Certified Persons must still demonstrate fitness and propriety annually; the Conduct Rules still reach almost everyone in a regulated firm. Firms whose training programmes communicate the PS26/6 changes should make this clear to staff: the regime is being streamlined, not relaxed.
For foundational context on how SM&CR works and what training must cover, see our guide to what is SM&CR training.
What is the SM&CR Phase 1 review and why does it matter?
PS26/6, published by the FCA in April 2026, is the first output of a review announced in 2023 as part of the UK government’s competitiveness agenda. The review had a clear remit: identify where SM&CR processes create administrative burden without delivering proportionate accountability benefits, and remove that burden.
Three areas received the most targeted reform: the SMF application and onboarding process, the scope and administration of the Certification Regime, and the mechanics of Prescribed Responsibilities and Statements of Responsibilities. The changes are practical rather than structural. The three-pillar architecture of SM&CR (Senior Managers, Certified Persons, Conduct Rules) is unchanged, as is the fundamental principle that named individuals, as well as firms, are accountable for regulated activities.
Phase 2 of the review, which may include more structural changes to the regime, requires primary legislation from HM Treasury and is expected to be consulted on later in 2026. This guide addresses Phase 1 only.
What changed on 24 April 2026?
Tranche 1 is already in force. If your firm has not reviewed these changes, the time to act is now.
Criminal records checks. CRC validity has extended from three months to six, and internal or intragroup moves no longer require repeat checks. The practical implication is a lighter administrative burden on HR during internal SMF appointments; update your recruitment and onboarding process documentation to reflect the new validity window.
The 12-week rule. This is the most training-significant change in Tranche 1. Under the previous rule, firms had 12 weeks to obtain FCA approval for an SMF; under PS26/6, they have 12 weeks to submit the application. The candidate can act in the role from day one, under Senior Manager Conduct Rules, while the application is pending. The training implication is immediate: anyone covering an SMF must receive Senior Manager Conduct Rules training before they take up the role, not after approval. If your induction training flow still assumes the old model (train after FCA decision), it needs revising now.
Prescribed Responsibilities. PS26/6 gives firms greater flexibility: PRs can now be split among multiple SMFs, and allocations beyond the standard examples are permitted with clear rationale. Where your firm takes advantage of this, the affected SMFs’ Statements of Responsibilities must be updated, and those individuals retrained on their revised scope of accountability.
Certification process. Digital certificates are now acceptable, and proportionate re-certification is permitted where no material changes have occurred since the last assessment. The certification cycle can align with annual appraisal. Update your certification communications to staff and ensure training records reflect any format changes.
What changes on 10 July 2026?
Tranche 2 is operationally the most significant for many firms and requires proactive preparation before the deadline.
Duplicate certification removed. Approximately 15% of certified roles will no longer require certification where overlapping requirements existed. Firms should audit their certified population now to identify which roles are affected. An important nuance: staff whose roles are removed from certification remain subject to the Conduct Rules and still need Conduct Rules training; only the annual fitness and propriety assessment is removed. Do not simply delete training assignments for de-certified roles.
Enhanced SM&CR firm thresholds raised. The threshold for Enhanced firm classification is raised by approximately 30%. Some firms currently classified as Enhanced will fall to Core; some Core firms may cross up to Enhanced. This matters for training: Enhanced and Core firms have different sets of Prescribed Responsibilities and SMF obligations. A firm that changes tier needs to revise its entire SM&CR training programme to match its new requirements. Check your threshold status before 10 July.
Directory reporting deadlines extended. Firms now have 20 working days (up from 10) to report additions and changes in the Financial Services Register, except for leavers, which remains seven working days. This is a process change, not a training content change, so update your compliance and HR process documentation.
SMF18 can hold any Prescribed Responsibility. The restriction limiting SMF18 holders at solo-regulated firms has been removed. Firms with SMF18s should review Statements of Responsibilities and ensure the updated scope is reflected in training materials.
The table below summarises all three tranches and the associated action for each:
| Change | Date in force | Training or process action needed |
|---|---|---|
| CRC validity extended (3 → 6 months) | 24 April 2026 | Update SMF recruitment process documentation |
| 12-week rule: submit, not obtain, approval | 24 April 2026 | Train covering SMFs from day one in role |
| PR splitting and flexible allocation | 24 April 2026 | Update SoRs; retrain affected SMFs on revised scope |
| Digital certification / proportionate re-cert | 24 April 2026 | Update certification communications to staff |
| Duplicate certification removal | 10 July 2026 | Audit certified population; update training assignments |
| Enhanced SM&CR threshold +30% | 10 July 2026 | Check tier; revise training programme if tier changes |
| Directory reporting: 20 working days | 10 July 2026 | Update compliance and HR process documentation |
| SMF18 can hold any Prescribed Responsibility | 10 July 2026 | Review SoRs; update affected training materials |
| COCON NFM amendments (PS25/23 aligned) | 1 September 2026 | Update COCON training (see NFM training guide) |
| Regulatory references: 4-week turnaround | 1 September 2026 | Update HR and compliance process documentation |
What changes on 1 September 2026?
Tranche 3 brings two changes. The more significant for training is the set of COCON amendments that align PS26/6 with FCA Policy Statement PS25/23 on non-financial misconduct. These extend COCON’s scope to cover serious bullying, harassment and violence at all SMCR firms, and add a disclosure obligation for Senior Managers under Conduct Rule SC4. All firms must update their Conduct Rules and COCON training before 1 September 2026 to reflect the expanded scope. For a full guide to what non-financial misconduct training must cover and who must be trained, see our article on FCA non-financial misconduct training 2026.
The second Tranche 3 change affects regulatory references. The turnaround guidance is reduced from six weeks to four, and the guidance now specifies that unproven allegations should not be included in regulatory references. Update HR and compliance process documentation accordingly.
What does PS26/6 mean for SM&CR training in practice?
The reform changes are spread across three dates, but the practical implications resolve into four action areas.
Audit your certified population before 10 July. Identify which roles currently requiring certification will be de-certified following the duplicate-removal change. Update training assignments, but remember these staff still need Conduct Rules training. Banking and asset and wealth management firms with large certified populations should prioritise this audit now.
Check your firm’s SM&CR tier before 10 July. If the raised Enhanced threshold means your firm changes classification, your training programme needs a structural review to match the obligations of the new tier. Insurance firms, many of which are FCA solo-regulated Core or Enhanced, should check their threshold position. Fintech and payments firms that have grown since their last threshold assessment should also review.
Update SMF induction and onboarding training immediately. The 12-week rule change is already in force. Any covering SMF must receive Senior Manager Conduct Rules training from the moment they take up the role. If your induction training still assumes the old sequence (train after FCA determination), revise it now.
Update COCON and Conduct Rules training before 1 September. The NFM COCON amendments require content updates to your all-staff Conduct Rules training and targeted training for Senior Managers and HR and compliance teams. See our FCA non-financial misconduct training 2026 guide for what each layer must cover.
For the broader programme context (how to structure training assignments, evidence completion and keep the programme current through regulatory change), see our guide to building a compliance training plan. The CityREPORTS platform tracks certified-population assignments and produces the completion records your firm needs as the reform dates pass.
What is Phase 2 of the SM&CR review?
Phase 1 addresses changes the FCA could make within its existing powers. Phase 2 may include more extensive reforms, potentially to the scope of the Certification Regime, the Senior Managers Regime, and the Financial Services Register, but requires primary legislation from HM Treasury. HMT has confirmed it intends to proceed with the necessary legislation. The FCA expects to consult on Phase 2 later in 2026.
Firms should monitor FCA consultation publications. This article will be updated when the Phase 2 consultation is published.
Common questions about the SM&CR Phase 1 reforms
What is FCA PS26/6? PS26/6 is the FCA’s Policy Statement for Phase 1 of the Senior Managers and Certification Regime review, published in April 2026. It introduces targeted simplifications to the regime across three implementation dates: 24 April 2026, 10 July 2026, and 1 September 2026. The changes cover criminal records checks, the 12-week approval rule, Prescribed Responsibilities, certification processes, firm thresholds, and COCON amendments aligning with the FCA’s non-financial misconduct guidance in PS25/23.
What SM&CR changes came into force on 24 April 2026? On 24 April 2026, PS26/6 introduced: CRC validity extended from three to six months with no repeat checks for internal moves; the 12-week rule reformed so firms have 12 weeks to submit (not obtain) SMF approval, with covering SMFs able to act in role under Senior Manager Conduct Rules from day one; greater flexibility for Prescribed Responsibilities; and digital certification permitted.
What SM&CR changes take effect on 10 July 2026? On 10 July 2026, overlapping certification requirements are removed (affecting approximately 15% of certified roles), Enhanced SM&CR firm thresholds are raised by around 30%, directory reporting deadlines extend to 20 working days, and SMF18 holders can hold any Prescribed Responsibility at solo-regulated firms. Firms should audit their certified population and check their tier before this date.
Does PS26/6 reduce accountability under SM&CR? No. The FCA’s stated position is that PS26/6 simplifies administrative processes without reducing accountability. Senior Managers retain personal accountability for their areas; Certified Persons must still demonstrate fitness and propriety; Conduct Rules still apply across the firm. The changes remove duplication and bureaucratic friction; they do not weaken the core accountability framework.
What training changes are needed for the July 2026 SM&CR reforms? The July 2026 changes require firms to audit their certified population, update training assignments (de-certified roles still need Conduct Rules training), and review their SM&CR tier. Firms that move between Enhanced and Core tiers need to revise their entire training programme for the new tier’s obligations.
What is Phase 2 of the SM&CR review? Phase 2 covers more extensive reforms requiring primary legislation from HM Treasury. HMT has confirmed it intends to proceed with these legislative changes; the FCA expects to consult on Phase 2 later in 2026. Phase 2 may include changes to the scope of the Certification Regime and the Senior Managers Regime. CityLearning will update this guide when the Phase 2 consultation is published.
CityLearning’s SM&CR training is updated for the PS26/6 Phase 1 reforms, covering all three pillars across Senior Managers, Certified Persons and Conduct Rules staff. The CityREPORTS platform tracks certified-population assignments and produces the completion records your firm needs as the reform dates pass. Request a demo to see how it maps to your current SM&CR programme.