The FCA’s latest policy statement has set out changes to the Senior Managers and Certification Regime that will come into effect from 24th April 2026. Policy Statement PS26/6 sets out the FCA’s first suite of changes to the Senior Managers and Certification Regime (SM&CR). The SM&CR came into effect in 2016 and is designed to ensure individual accountability, with these changes intended to make the regime work more efficiently and proportionately. These changes apply to all FCA solo‑regulated and dual‑regulated firms from 24th April 2026.
Phase 1 focuses on adjustments that can be made without changes to legislation and aims to cut out duplication, reduce administrative effort and give firms more flexibility, without weakening standards. The scope of Phase 2 has not been defined yet, but a consultation can be expected later this year.
Key changes introduced by PS26/6
- Criminal record checks: Their validity is increased from 3 months to 6 months, and they are no longer required for internal moves.
- 12‑week rule: Firms now have the full 12-week period to submit the SMF application, with candidates able to act in the role until determination.
- Senior Management Functions (SMFs) 7 & 18: Further guidance has been provided on the scope of SMF 7 & SMF 18 roles.
- Statements of Responsibilities and Responsibilities Maps: Firms can submit changes up to 6 months after they have been made.
- Fit & Proper (F&P) Regime: Certification can be incorporated into annual appraisals, with emails being sufficient evidence of F&P certification.
- Directory Updates: Firms are given 20 working days (increased from 7) to update Financial Services directory information.
- Regulatory References: Firms must respond to regulatory reference requests within 4 weeks (reduced from 6 weeks).
- Conduct Rules and prescribed responsibilities: Further guidance on notification of Conduct Rule breaches has been provided.
- Enhanced firm threshold: Criteria for being an enhanced firm will be updated every 5 years to keep up with inflation.
How Thistle Initiatives Can Help
- We can help your firm submit SMF applications.
- We can assist with writing SM&CR policies.
- We can undertake an audit of your firm’s SM&CR framework.
Meet the Expert
Melissa Buckingham, Compliance Consultant 
Melissa joined Thistle Initiatives in 2025, bringing with her a strong background in managing conflicts of interest and cross-border regulatory activity from her time at a Tier 1 bank.
With a deep understanding of both the regulatory landscape and operational pressures facing firms, Melissa adopts a thorough and detail-oriented approach to helping clients achieve and maintain compliance. She supports clients across a range of sectors, but primarily in the investments and wealth management space.