SMCR Phase 1 Reform 2026: what the FCA’s policy statement actually changes
Why the FCA Is Reforming SMCR The Senior Managers and Certification Regime (SMCR) has been the framework for individual accountability in UK financial services since 2016 for banks and 2019 for solo-regulated firms. After more than five years of full operation, HM Treasury commissioned a …
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 …
UK Compliance Recruitment 2026: DORA, CASS & TPR Hiring
Why are UK FCA-regulated firms suddenly competing so intensely for three specific senior compliance disciplines — DORA Compliance Officers, CASS leadership including SMF18 holders, and Heads of Third-Party Risk Management — and what is driving the recruitment market for these roles to tighten faster than …
What Is a Section 166 Review? FCA Skilled Person Guide
What Is a Section 166 Review? FCA Skilled Person Guide Introduction to Section 166 Review Overview of the Financial Conduct Authority (FCA) The Financial Conduct Authority (FCA) is a regulatory body in the United Kingdom responsible for overseeing the conduct of financial firms to ensure …
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