SM&CR training is mandatory for all staff subject to the Conduct Rules at FCA-regulated firms, in practice almost everyone. Training must be tiered by role: Senior Managers receive training on Statements of Responsibilities; Certified Persons on fitness and propriety; and all other staff on the five Individual Conduct Rules. Annual refreshers are the industry standard.
SM&CR training is the training UK regulated firms must provide to help staff understand and meet their obligations under the Senior Managers and Certification Regime. The regime, introduced by the FCA and the Prudential Regulation Authority (PRA), holds individuals, as well as firms, personally accountable for their conduct and the areas they run. The training obligation touches almost everyone in a regulated firm, but it differs by tier. Many firms make the same two mistakes: training the wrong people on the wrong things, or treating SM&CR as a one-off induction module.
This guide explains what the regime is, who needs training, what that training must cover, and what the FCA means by ‘suitable’ training. It explains what the rules require; it is not legal advice.
What is the SM&CR?
The Senior Managers and Certification Regime (SM&CR) is the FCA and PRA framework that replaced the Approved Persons regime. Introduced to banks in 2016 and extended to all FCA solo-regulated firms from December 2019, its central shift is personal accountability: individuals are answerable for their own conduct and for the areas they run, as well as for the firm as a whole. The regime operates through three pillars:
- The Senior Managers Regime: the most senior decision-makers hold approved Senior Management Functions (SMFs) and a Statement of Responsibilities for the areas they run.
- The Certification Regime: individuals whose role could cause significant harm to customers or markets are certified by the firm rather than the FCA, and reassessed each year.
- The Conduct Rules: a set of basic standards of behaviour that apply across the firm.
Our SM&CR training course covers all three pillars.
Who does SM&CR training apply to?
Training is tailored across three tiers:
Senior Managers (SMFs). Individuals approved by the FCA or PRA for a Senior Management Function. Their training must reflect their specific SMF and the areas they run, and must build a working understanding of their Statement of Responsibilities and what taking ‘reasonable steps’ means in practice.
Certified Persons. Individuals whose role could cause significant harm to customers or markets. The firm certifies them as fit and proper, and must do so annually. Their training must support that ongoing fitness and propriety assessment.
All other Conduct Rules staff. In practice, almost everyone else in the firm, with limited exceptions for purely ancillary roles (such as catering or cleaning). Their training must ensure they understand the Individual Conduct Rules and how each one applies to their own work.
The FCA’s own expectation is that training should give staff ‘awareness and a broad understanding of all the conduct rules, and a deeper understanding of the practical application of the specific rules relevant to their work’. Tiering training to role is therefore how firms meet the standard.
What must SM&CR training cover?
SM&CR training must cover the five Individual Conduct Rules for all Conduct Rules staff, the Senior Manager Conduct Rules and Statements of Responsibilities for those holding SMFs, and fitness and propriety requirements for Certified Persons, with each tier tailored to the individual’s role and accountability.
For all Conduct Rules staff: the five Individual Conduct Rules: act with integrity; act with due skill, care and diligence; be open and cooperative with regulators; pay due regard to the interests of customers and treat them fairly; and observe proper standards of market conduct. Training must show how each rule applies to that person’s actual role. Our FCA Conduct Rules course is built around this.
For Senior Managers: the Senior Manager Conduct Rules (SC1–SC4) in addition to the Individual Conduct Rules, plus a practical understanding of Statements of Responsibilities and what ‘reasonable steps’ look like for their area.
For Certified Persons: the fitness and propriety standards (honesty, integrity and reputation; competence and capability; and financial soundness) and the annual certification process. Our SM&CR course covers the fit and proper assessment in depth.
How often must firms provide SM&CR training?
The FCA requires SM&CR training when rules first apply to an individual and as expectations evolve. Annual refreshers are the industry standard. Training must also be updated following regulatory changes, including the 2026 PS26/6 reforms, and after conduct findings or role changes.
The FCA expects firms to train Conduct Rules staff when the rules first apply to an individual (on appointment, or when they first become subject to the regime) and to provide ongoing training as expectations evolve.
- Annually is the industry norm for refresher training. The FCA expects staff to understand the rules as they currently apply, keeping pace with how expectations have moved since induction.
- On regulatory change, including the FCA’s ongoing SM&CR simplification work in 2026, update training to match.
- Event-driven: if a Certified Person’s role changes, or there is a conduct finding in the firm, targeted training is expected.
What does ‘suitable’ SM&CR training look like?
Suitable SM&CR training is role-specific, scenario-based to show how Conduct Rules apply in real decisions, assessable with a configurable pass mark, and documented with time-stamped completion records. A single awareness slide-deck for the whole firm does not meet the standard.
The FCA’s language is ‘suitable training’, appropriate to the individual’s role, tier and responsibilities. In practice that means:
- Role-specific. A single awareness slide-deck for the whole firm does not meet the standard.
- Scenario-based. Showing how the Conduct Rules play out in realistic workplace decisions.
- Assessable. A completed module alone does not demonstrate understanding. Assessment questions and a pass mark create a defensible record.
- Documented. Completion records should show who completed training, on what, and when: the evidence a supervisor will ask for. See our guide to building a compliance training plan, and the CityREPORTS platform for completion records by tier and role.
How does SM&CR training connect to Consumer Duty?
SM&CR and Consumer Duty training often run alongside each other because both ask the same underlying question: what is this individual accountable for, and do they understand their obligations? Senior managers responsible for customer-facing activities carry personal accountability under both frameworks simultaneously.
The Consumer Duty, in force since 2023, added a further layer of accountability: firms must deliver good outcomes for retail customers, and the responsibility is personal for those who design products, set prices, or support customers. SM&CR and Consumer Duty training often run alongside each other because both ask the same underlying questions: what is this individual accountable for, and do they understand their obligations?
Common questions about SM&CR training
What is SM&CR training? It is the training UK regulated firms must provide so staff understand and meet their obligations under the Senior Managers and Certification Regime. The regime, introduced by the FCA and PRA, holds individuals personally accountable for their conduct and the areas they run. Training must cover the Conduct Rules, individual accountability and, for Senior Managers, reasonable steps and Statements of Responsibilities. The FCA expects training to produce understanding, evidenced by more than attendance.
Who needs SM&CR training? It applies to all staff subject to the Conduct Rules, in practice almost everyone in an FCA-regulated firm, with limited exceptions for purely ancillary roles. Training must be tailored by tier: Senior Managers need depth on their Statements of Responsibilities; Certified Persons need to understand fitness and propriety; and all Conduct Rules staff must understand the Individual Conduct Rules in the context of their own role.
How often must firms provide SM&CR training? The FCA requires firms to train Conduct Rules staff when the rules first apply to them, and to provide ongoing training as expectations evolve. Annual refreshers are the industry norm. Training should also be updated when the FCA issues new guidance, when an individual changes role, or following a conduct finding in the firm.
What should SM&CR training include? The five Individual Conduct Rules and how they apply to each person’s role; the Senior Manager Conduct Rules for those in SMF positions; fitness and propriety requirements for Certified Persons; and the implications of personal accountability. The FCA expects scenario-based content that builds practical judgement, and firms should keep records of completion and assessment results.
CityLearning’s SM&CR training course covers all three tiers (senior managers, certified persons and all-staff Conduct Rules) with scenario-based content that shows how the rules apply in real decisions. The CityREPORTS platform records completion by tier and role, giving you the evidence the FCA expects. Request a demo to see how it fits your firm.