SMCR vs APR: what was lost when the Approved Persons Regime was retired
The Regime That SMCR Replaced For twenty years, the Approved Persons Regime (APR) was the FCA’s primary framework for holding individuals at regulated firms to account. Introduced under the Financial Services and Markets Act 2000, the APR required firms to obtain FCA approval for anyone …
SMCR for Limited Scope firms: what changes if you’re a Limited Scope firm
What Is a Limited Scope Firm Under SMCR? When the Senior Managers and Certification Regime (SMCR) was extended to solo-regulated firms in December 2019, the FCA recognised that a single framework applied uniformly to every authorised firm would be disproportionate. The result was a three-tier …
Distribution Chain Obligations Under Consumer Duty: Who Does What
Distribution Chain Obligations Under Consumer Duty: Who Does What Manufacturer and Distributor Responsibilities, Information Flow, and Recruitment Implications For UK financial services products that pass through distribution chains — funds distributed through platforms and advisers, insurance products distributed through brokers, mortgage products distributed through brokers, …
Fair Value Assessments Under Consumer Duty: A Practical Framework
Methodology, Data Inputs, and the Substantive Analytical Standard the FCA Expects Fair value assessment is the most operationally demanding component of the Price and Value outcome under Consumer Duty, and the area where the gap between strong and weak firm practice has widened most visibly …
The Consumer Duty Annual Board Report: What Good Looks Like in 2026
The Consumer Duty Annual Board Report: What Good Looks Like in 2026 From First-Cycle Documentary Compliance to Substantive Outcome Evidence The Consumer Duty annual board report is now in its third cycle for most UK regulated firms. The first cycle (July 2024) saw firms producing …
How Consumer Duty Has Reshaped the SMF16 Compliance Oversight Role
From Conduct Compliance Manager to Substantive Customer Outcomes Owner The 2023 introduction of Consumer Duty under PS22/9 has done more than tighten conduct expectations — it has structurally reshaped what the SMF16 Compliance Oversight role actually involves day-to-day. Where the role historically combined conduct rule …
The Fractional CFO’s Playbook for PE-Backed Businesses
What does fractional Chief Financial Officer engagement actually deliver for a UK PE-backed business What specific finance disciplines do PE sponsors expect substantively executed against, what does a typical fractional CFO 100-day plan look like inside a portfolio company, how do sponsor reporting cycles, value …
The Complete Guide to NEDs in UK Businesses
What is a Non-Executive Director What does the role actually involve in a UK business context, what are the personal accountability frameworks under the Companies Act 2006 directors’ duties and the FRC UK Corporate Governance Code, how does NED service differ across listed companies, PE-backed …
The CFO’s Guide to SaaS and Subscription Businesses
What makes Software-as-a-Service and subscription business finance genuinely distinctive from traditional product or service business finance The recurring revenue economics, the cohort-based diagnostic discipline, the specific revenue recognition treatments under IFRS 15 and FRS 102, the metrics ecosystem from Annual Recurring Revenue through Net Revenue …
The CFO’s Guide to Cybersecurity Risk
Why has cybersecurity risk moved from being a purely technology and information security concern into a substantive Chief Financial Officer responsibility, what specific dimensions of cyber risk does the modern UK CFO need to engage with substantively rather than delegate entirely to the Chief Information …
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