How to Apply to Become an Approved Person: The FCA Process

Becoming an FCA-approved person — whether as a Senior Manager Function holder at an existing firm or during a new firm’s authorisation — requires a formal application process, a detailed personal disclosure, and the FCA’s active assessment of your fitness and propriety to perform the role.

Under the Senior Managers and Certification Regime, individuals performing Senior Manager Functions must be individually approved by the FCA. The approval process — colloquially known as the “approved person” process — is not a rubber stamp. The FCA carries out a genuine assessment of each applicant’s fitness and propriety, and it is not uncommon for applications to generate queries, require additional information, or take longer than expected where the FCA has concerns about any aspect of the applicant’s background.

Who Needs FCA Approval?

Any individual proposed to perform a Senior Manager Function at an FCA-regulated firm must be approved by the FCA before beginning the function. The requirement applies to: new appointees to SMF roles at existing authorised firms; founding management team members at firms going through initial authorisation; individuals taking on additional SMF roles they have not previously held; and individuals returning to SMF roles after a period in which they were not performing any SMF function at an FCA-regulated firm.

It is important to note that FCA approval is role-specific: approval as SMF16 (Compliance Oversight) does not automatically entitle the individual to perform SMF17 (MLRO). Each function requires separate approval through a separate application, though where an individual holds multiple SMF roles at the same firm, all applications are typically submitted simultaneously and processed together.

The Form A Application

Applications for SMF approval are submitted through FCA Connect using Form A. The form is submitted by the firm on behalf of the individual — the firm is the regulated entity making the appointment, and takes responsibility for the accuracy of the application. This does not reduce the individual’s own responsibility for the accuracy of their personal disclosures, which they must verify and sign off.

Form A requires the following principal disclosures from the applicant:

Personal details and identity. Full name, date of birth, nationality, and details of any name changes or previous names used.

Employment history (five years). A complete employment history covering the five years prior to the application date, including all regulated and unregulated employment, self-employment, directorships and periods of unemployment or absence from work. Gaps in employment history attract FCA attention and should be explained clearly.

Regulatory history. Any previous approvals as an FCA approved person, SMF holder or equivalent; any refusals, withdrawals or lapses of approval; any regulatory sanctions, prohibition orders or conditions imposed on the individual; and any disciplinary action by a regulated firm related to regulatory matters.

Criminal history. Any criminal convictions — including spent convictions where the individual is required to disclose them under the Rehabilitation of Offenders Act exceptions applicable to financial services. Cautions, reprimands and warnings must also be disclosed where relevant.

Civil proceedings. Any court judgments, arbitration findings or regulatory decisions made against the individual in connection with financial services activities, dishonesty, fraud or other conduct relevant to fitness and propriety.

Financial soundness. Any county court judgments, insolvency events, individual voluntary arrangements, or current financial difficulties that could affect the individual’s judgment or create conflicts of interest in the SMF role.

Statement of Responsibilities

Each Form A application must be accompanied by a Statement of Responsibilities — the document defining what the individual will be accountable for in their SMF role. The SoR must be specific and accurate: it should describe the individual’s actual responsibilities at the firm, not a generic description of what someone in that function typically does. The FCA reviews SoRs for adequacy and will query applications where the SoR is too vague to allow meaningful accountability assessment.

Regulatory References

Where the applicant has worked at another FCA-regulated firm in the previous five years, the FCA requires a regulatory reference from that firm — a structured disclosure covering whether the applicant has been subject to any regulatory action, disciplinary action for conduct matters, or findings relevant to fitness and propriety. The reference obligation falls on the previous employer, and the applicant should request it promptly. Delays in obtaining references are among the most common causes of SMF approval delays.

The FCA can proceed with an application in the absence of a regulatory reference where the applicant can demonstrate that reasonable steps have been taken to obtain it without success. Documenting the steps taken — emails sent, follow-up calls made, escalation to senior contacts at the previous employer — and providing this documentation to the FCA proactively is important where a reference is proving difficult to obtain.

How the FCA Assesses Fitness and Propriety

The FCA’s fitness and propriety assessment covers three dimensions: honesty, integrity and reputation; competence and capability; and financial soundness. The weight given to each dimension varies with the specific SMF being applied for, the firm’s regulatory risk profile and the information disclosed in the application.

Honesty, integrity and reputation is assessed primarily from the Form A disclosures and regulatory reference. The FCA is particularly sensitive to: previous regulatory or enforcement action, even where it did not result in formal findings; civil proceedings suggesting dishonest or misleading conduct; adverse media coverage relating to the applicant’s professional conduct; and any indication that the Form A disclosure is incomplete or misleading.

Competence and capability is assessed by reference to the applicant’s experience and qualifications for the specific function being applied for. For SMF16 (compliance officer), the FCA expects the applicant to have regulatory knowledge relevant to the firm’s activities — generic compliance experience in unrelated sectors is insufficient. For SMF17 (MLRO), AML-specific knowledge and practical DAML experience are expected. Where the FCA has doubts about competence, it may request a competence interview or additional evidence of qualifications.

Financial soundness is assessed from the Form A financial disclosures. CCJs, insolvency events and current financial difficulties do not automatically prevent approval, but they require explanation — the FCA will want to understand the circumstances and satisfy itself that the financial history does not create conflicts of interest or judgment concerns in the SMF role.

Typical Timelines and Common Queries

Straightforward SMF applications with complete disclosures, adequate regulatory references and a clear SoR are typically determined within three to six weeks of submission. Applications that generate queries — because of adverse disclosure, incomplete references, a vague SoR, or concerns about competence — can take significantly longer.

The most common FCA queries on SMF applications are: requests for further explanation of gaps in employment history; clarification of the circumstances of previous regulatory action or civil proceedings; supplementary evidence of qualifications or experience for specific functions (particularly SMF16 and SMF17); and requests to revise the SoR to make it more specific.

Where the FCA issues a query, the firm and the applicant should respond promptly, completely and clearly. Partial or evasive responses extend the process and sometimes prompt additional enquiries. If the matter the FCA is querying is genuinely complex — for example, a previous regulatory investigation that was resolved without formal findings — consider engaging regulatory legal advice before responding.

Key References

• FCA — Senior Managers Regime: approvals guidance
• FCA Connect — for submitting Form A applications
• FCA Handbook FIT — the fit and proper sourcebook