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The Senior Managers & Certification Regime (SM&CR) replaced the previous Approved Persons regime for all solo regulated firms* on 9 December 2019. SM&CR significantly raised the bar for standards of personal conduct and put a new more stringent emphasis on management accountability.

The Senior Managers & Certification Regime impacts, not just board members and senior managers but, anyone who’s involved in any aspect of regulated activity.

What you need to know about SM&CR

The regime replaced the category of Approved Persons with that of senior managers and charges senior managers with a range of responsibilities.

As well as looking at senior managers, SM&CR also requires firms to identify individuals in the next tier down of management and those performing certain specific roles (certification functions). At least once a year, firms must evaluate and certify these named individuals’ fitness for the roles they perform.

SM&CR also introduced criminal record checks for both senior managers and non-executive directors for most firms and a template that firms must use to provide regulatory references for senior managers and staff in certification function roles.

Another significant difference is that there are now specific conduct rules that apply to all staff (other than those in ancillary roles, e.g. cleaners). Staff impacted by the conduct rules need regular training on how these rules apply to their roles. SM&CR includes additional rules for senior managers and requires any breaches of the rules which result in disciplinary action to be reported to the regulator.

What you need to do to comply with SM&CR

The first Senior Managers & Certification Regime deadline was on 9 December 2019. By this date, firms needed to have senior managers holding the correct senior manager functions, to have identified their certified staff, and to have trained these staff and senior managers in the conduct rules.

The next deadline fell on 31 March 2021, by when firms needed to collect evidence to demonstrate that certified staff are suitable to carry out their roles so that they could issue their certificate. All other staff impacted by the conduct rules must have been trained in the rules as they apply to their roles. You will also need to have uploaded information on Directory Persons to the FCA Directory via Connect before the deadline.

There was a lot involved in making sure firms comply with the new regime – but help is at hand.

As a starting point, you can download a sector-specific version of our document 10 Steps to SM&CR Compliance (available in three sector-specific versions) by clicking on one of the links below:

How can we help?

We’re already helping hundreds of firms comply with the regime, walking them through the various elements of SM&CR, explaining how this impacts their businesses, reviewing their arrangements, providing expert advice, and answering a host of questions.

We’ll review your current SM&CR arrangements and provide advice and suggestions for improvement if required.

We also offer face-to-face training and online courses for other staff impacted by the conduct rules to ensure you have completed all the necessary training.

We can help you with your certification process, making sure you have the tools in place to confirm suitability and issue the certificate before the deadline.

* SM&CR does not apply to payment services firms (this may change in future) Appointed Representatives

Compliance Star

You can also benefit from our on-demand compliance software Compliance Star.

Compliance Star Compliance Star platform image

Senior Managers & Certification Regime

Compliance Star gives you the tools you need to keep your firm up to compliance standards and allows you to select from a package of modules, including SM&CR, which can be tailored to your needs and requirements.

The SM&CR module integrated into the suite of Compliance Star applications is designed to capture all the relevant functions and responsibilities that apply across organisations and key individuals.


    • Statement of Responsibilities reporting, workflow and approval including prescribed and other responsibilities
    • Workflow to manage and evidence conduct risk training, breaches and tasks
    • A section recording all certification regime employee due diligence and the issue of a certificate confirming the individual has been assessed as competent for the role
    • Automated process and workflow for ongoing assessments of the fitness and propriety of senior managers and certification employees.


    • Meets regulatory requirements for information you need to hold on individuals
    • Dashboards and MI highlight any issues or gaps in your documentation
    • Automated tasks ensure ongoing due diligence
    • Audit trail of all communications, both internal and external.

To find out more about all the features and benefits of Compliance Star, to request a demo or speak to a member of the team please call 0203 859 0056 or visit

Senior Managers

Since we started in 2012, we’ve helped many individuals right across the financial services sector gain FCA Approved Persons status.

Guiding you through the Senior Manager process

We know exactly what the FCA is looking for. We understand in detail what information it needs from individuals applying for Senior Manager status. We also know how to frame responses so as to keep queries to a minimum.

We’ll support your application every step of the way. Before anything goes to the FCA, we’ll talk you through the questions in the application form, and all the information you’ll need to gather. We’ll alert you to any flags that could trigger questions or concerns from the FCA – and how best to address them.

We can also provide training to make sure you’re fully equipped for your role. The regulator will sometimes request an interview before granting approval. If that happens, we can give you specific advice on how to handle this, and we can role-play the interview, so you’ll feel confident and well prepared.

We can also help firms recruiting for senior manager positions. For example, we can draw up role descriptions and sit in on interviews to make sure you find the right person.

How our Senior Manager process works

We’ll provide a free initial consultation to discuss the senior manager role and how we can help, and then provide a quote for the support you’re looking for.

We’ll supply you with the relevant FCA forms and talk you through what information and supporting documentation the regulator requires.

We can review a draft form you’ve already completed yourself and review your CV, identifying any points we think might give rise to queries.

We’ll deal with any correspondence you may need to engage in with the regulator, right through to approval being granted.

We can provide you with access to our Knowledge Centre for senior manager training or provide one-to-one onsite training if you prefer.

In short, we can help make sure your application is in the best possible shape to get you accepted as a senior manager. We have the knowledge and skills to take the stress out your senior manager application, and extensive experience across a broad range of sectors.

For more information about our Senior Managers & Certification Regime services, call 0207 436 0630 to speak to a member of our expert team or email

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