In July 2025, the FCA and Prudential Regulation Authority (PRA) confirmed a series of proposed changes to the Senior Managers & Certification Regime (SM&CR). The aim is to make the regime more efficient whilst still maintaining a high standard of conduct and accountability.
Thistle works closely with firms across the financial services sector to implement, review, and embed SM&CR requirements in a proportionate and practical way. These changes reflect many of the challenges we see firms navigating in practice, particularly during periods of growth, restructuring, or leadership change.
Below, we explore the proposals and what they mean for regulated firms.
The FCA and PRA are proposing to enhance the guidance currently available to firms on conducting annual fit and proper assessments. This will allow firms to navigate this core obligation with more efficiency and have a consistent approach to follow.
7. More Flexibility for Temporary Appointments
The FCA will be granting more leniency in the event of a temporary appointment being required for a firm. This will provide firms with longer windows in submitting applications for new senior managers, especially in the event of an unexpected or temporary change.
8. Extended Updates to FCA Directory
Firms will be given the opportunity to update the FCA Directory of certified staff with reduced time constraints. This will enable firms to update the FCA Directory in a more efficient and accurate manner.
Whilst the above proposals are promising, the FCA has emphasised that the purpose of SM&CR remains pivotal. The reforms proposed are not intended to reduce the regime’s effectiveness, but rather to remove unnecessary requirements that may hinder growth for firms and therefore disadvantage consumers.
Thistle Initiatives supports firms in adapting to regulatory change. We help review SM&CR functions, update internal processes, and prepare for regulatory submissions in line with the proposed reforms.
If you’d like to discuss how these changes could affect your firm’s SM&CR obligations, please get in touch.
Anisha is a compliance specialist with over six years of experience in financial services, specialising in FCA regulations and OFSI sanctions. She has successfully implemented global compliance programs, introduced cost-saving monitoring systems, and ensured adherence to regulatory requirements.
Anisha's expertise spans sanctions analysis, regulatory risk mitigation, policy drafting, and compliance audits. With a proven track record in reducing compliance risks and managing high-stakes regulatory projects, she brings technical precision and leadership to every role.