SMCR Support: Find Senior Compliance and Risk Leaders Who Have Run the Regime Before

The Senior Managers and Certification Regime — universally abbreviated to SMCR — is the UK’s individual accountability framework for people working in FCA-regulated financial services firms. It came into force for banks in March 2016, was extended to insurers in December 2018, and was extended to all FCA solo-regulated firms in December 2019. SMCR now covers approximately 50,000 firms and hundreds of thousands of individuals across UK financial services. It is the most significant change in individual regulatory accountability in UK financial services since the original Financial Services and Markets Act 2000.

SMCR has three pillars: the Senior Managers Regime (the named individuals performing Senior Management Functions who carry personal accountability), the Certification Regime (employees whose role could cause significant harm, certified annually by the firm as fit and proper), and the Conduct Rules (behavioural standards that apply to almost all staff). Together, these three pillars create a framework where responsibility for regulatory outcomes is allocated to specific named individuals rather than sitting diffusely across the firm — and where those individuals can be held personally accountable for failings in their areas of responsibility.

For senior compliance, risk and HR leaders, SMCR is a substantial ongoing obligation: maintaining Statements of Responsibilities, running annual certification, managing regulatory references, training staff on the Conduct Rules, notifying the FCA of breaches, and handling the governance that sits around all of this. Getting SMCR right is not a one-off implementation task — it is a permanent operating discipline that firms live with every day.

This guide sets out what SMCR is, the detail of the three pillars, the specific senior management functions firms must staff, the prescribed responsibilities that must be allocated, the personal accountability mechanisms that make SMCR different from earlier regimes, common implementation failures, and how FD Capital places the senior compliance, risk and governance specialists who make SMCR work in practice.

What SMCR Actually Is — and What Preceded It

Understanding why SMCR exists helps explain what it requires. The regime did not emerge in a vacuum — it was a specific response to failures in the earlier Approved Persons Regime that the 2013 Parliamentary Commission on Banking Standards identified in the aftermath of the 2008 financial crisis and the subsequent LIBOR, PPI and other conduct failures.

The Approved Persons Regime that SMCR replaced

Before SMCR, the Approved Persons Regime (APR) was the FCA’s framework for individual accountability in regulated firms. Individuals performing “controlled functions” required FCA approval and were subject to the Fit and Proper test and the Statements of Principle for Approved Persons (APER). The regime was long-established, widely understood, and had serious weaknesses.

The Parliamentary Commission identified specific problems: accountability was diffuse (many approved persons, few with clearly defined responsibilities); enforcement was difficult (hard to prove any individual responsible for a specific failing); and senior managers could escape accountability by claiming they were not personally aware of issues in their areas. The Commission’s conclusion was that the UK needed a regime where specific named individuals held specific defined responsibilities, and where those individuals could be held to account when things went wrong.

The SMCR response

SMCR implements that approach. Senior Managers are a smaller group than the former approved persons, but each has a Statement of Responsibilities setting out exactly what they are accountable for. Prescribed Responsibilities ensure certain specific responsibilities are always allocated to a named Senior Manager. The Duty of Responsibility makes senior managers personally liable for regulatory failings in their areas if they did not take reasonable steps to prevent them. And the Certification Regime and Conduct Rules extend behavioural standards beyond the senior management layer to a much wider population of staff.

Timeline of SMCR rollout

March 2016: SMCR came into force for banks, building societies, credit unions and PRA-designated investment firms.
December 2018: Extended to insurers, with a tailored set of Senior Management Functions reflecting insurance firm governance.
December 2019: Extended to all FCA solo-regulated firms — investment firms, asset managers, consumer credit firms, mortgage lenders, insurance intermediaries, financial advisers and the full population of FCA-authorised firms.
Ongoing: Successive handbook changes have refined the regime. Most notably, the Consumer Duty (2023) introduced additional expectations on how Senior Managers should consider customer outcomes within their responsibilities.

The Three Pillars of SMCR

Understanding the three pillars and how they relate is essential. They are distinct frameworks operating together, not a single unified regime.

Pillar 1: The Senior Managers Regime

The Senior Managers Regime applies to the named individuals performing Senior Management Functions. Firms must:

Identify who is performing each applicable SMF at the firm
Apply to the FCA for approval of each Senior Manager before they can perform their SMF
Produce and maintain a Statement of Responsibilities (SoR) for each Senior Manager
Allocate Prescribed Responsibilities to Senior Managers
For Enhanced firms, maintain a Management Responsibilities Map (MRM)
Ensure ongoing Fit and Proper assessment
Apply the Senior Conduct Rules to Senior Managers

The Senior Managers population is deliberately smaller than the old approved persons population — at most firms, a typical SMF list runs to between 5 and 20 named individuals, depending on firm size and complexity.

Pillar 2: The Certification Regime

The Certification Regime applies to employees (other than Senior Managers) whose role could cause significant harm to the firm or its customers — the “Certified Persons”. Firms must:

Identify which roles fall within the certification population
Certify each certified person as fit and proper to perform their role — annually
Not employ anyone as a certified person who has not been certified
Keep records of the certification decision and supporting evidence
Apply the Individual Conduct Rules to all certified persons

Unlike Senior Managers, certified persons do not require FCA approval — the firm makes the certification decision itself. But the firm is accountable for the decision, and poor certification practice is a recurring area of FCA supervisory attention.

Pillar 3: The Conduct Rules

The Conduct Rules apply to almost all staff at the firm, not only Senior Managers and certified persons. There are two tiers:

Senior Conduct Rules (SC1–SC4): Additional rules applying only to Senior Managers.
Individual Conduct Rules (COCON 2.1): Five rules applying to all in-scope staff — act with integrity, act with due skill care and diligence, be open and cooperative with regulators, pay due regard to customer interests and treat them fairly, observe proper standards of market conduct. A sixth rule added with Consumer Duty requires acting to deliver good outcomes for retail customers.

Firms must train all in-scope staff on the Conduct Rules, notify the FCA of any Conduct Rule breaches that result in disciplinary action, and apply the rules consistently in their internal disciplinary processes.

Senior Management Functions — the Named Roles

Each Senior Management Function (SMF) is a specific regulated role. The FCA maintains the list of SMFs, and firms within scope must determine which SMFs apply to them based on their permissions and structure. Some SMFs are universal; others apply only to specific firm types.

Core SMFs that apply across most FCA-regulated firms

The most commonly encountered SMFs include:

SMF1 — Chief Executive Function. The most senior operational role at the firm, typically the CEO.
SMF2 — Chief Finance Function. The CFO or Finance Director. Covers overall responsibility for the firm’s financial affairs, financial reporting, and related controls.
SMF3 — Executive Director. Each executive member of the board not otherwise covered by a more specific SMF.
SMF4 — Chief Risk Function. The Chief Risk Officer or Head of Risk. See our CRO recruitment page for more on this role.
SMF5 — Head of Internal Audit. The individual responsible for the internal audit function.
SMF7 — Group Entity Senior Manager. Where a senior individual at the group level exerts significant influence over the UK regulated firm’s affairs.
SMF9 — Chair. The Chair of the Board.
SMF10 — Chair of the Risk Committee.
SMF11 — Chair of the Audit Committee.
SMF12 — Chair of the Remuneration Committee.
SMF13 — Chair of the Nominations Committee.
SMF14 — Senior Independent Director.
SMF16 — Compliance Oversight Function. The individual with overall responsibility for the firm’s compliance with FCA rules. Often the Chief Compliance Officer.
SMF17 — Money Laundering Reporting Function. The MLRO — covered in detail in our MLRO guide.
SMF18 — Other Overall Responsibility Function. Captures individuals with overall responsibility for a specific activity or business area who do not fall within another SMF.
SMF24 — Chief Operations Function. The Chief Operating Officer where the firm has one. Applies to Enhanced firms and some Core firms.
SMF27 — Partner Function. At partnerships rather than incorporated firms, each partner typically holds SMF27.

Enhanced firm additional SMFs

For the largest FCA-regulated firms (“Enhanced firms” — those meeting specific size thresholds), additional SMFs apply. These include functions like Head of Key Business Area (SMF6) and others that apply to more complex firm structures. The Enhanced regime also adds substantive additional requirements including Management Responsibilities Maps and more extensive Prescribed Responsibilities.

Bank and insurer specific SMFs

PRA-designated banks have additional SMFs covering areas like Head of Treasury, Head of Key Business Area, and others not relevant for solo-regulated firms. Insurers have their own set of SMFs reflecting insurance-specific governance (e.g. Chief Actuary, With-Profits Actuary).

Which SMFs apply to which firm type

Firms fall into one of three SMCR tiers:

Limited Scope firms: Small firms with limited regulatory footprint (some consumer credit-only firms, for example). A reduced set of SMFs applies.
Core firms: The default tier for most FCA-regulated firms. Standard SMF set applies.
Enhanced firms: Largest and most complex firms. Full SMF set plus additional governance requirements (MRMs, overall responsibility mapping).

Determining which tier a firm falls into is a specific SMCR exercise, driven by the firm’s activities, revenue, assets under management or other relevant thresholds depending on business type.

Prescribed Responsibilities — What Must Always Be Allocated

Prescribed Responsibilities (PRs) are specific responsibilities the FCA requires to be allocated to a named Senior Manager. Unlike other areas of responsibility that the firm allocates as it sees fit, PRs must exist and must sit with a specific SMF holder. They are the FCA’s way of ensuring that certain critical areas always have a named individual accountable for them.

The core Prescribed Responsibilities

Core firms have a set of Prescribed Responsibilities including (in paraphrased form):

Performance by the firm of its obligations under the Senior Managers Regime
Performance by the firm of its obligations under the Certification Regime
Training of employees in the firm’s Code of Conduct rules
Responsibility for the firm’s policies and procedures on countering financial crime
Overall responsibility for the firm’s AML framework (typically allocated to SMF17)
Compliance with the UK’s equivalent of Solvency II / equivalent prudential regime as applicable
Responsibility for the firm’s internal audit function
Responsibility for the firm’s compliance with the client assets rules (where applicable)
Responsibility for the firm’s performance on Consumer Duty outcomes (added via later handbook changes)

Enhanced firms have a substantially longer list of Prescribed Responsibilities, reflecting the greater complexity of those firms. Each PR must be allocated to one specific Senior Manager — PRs cannot be shared jointly, and cannot be left unallocated. Firms must document the allocation in Statements of Responsibilities and, for Enhanced firms, the Management Responsibilities Map.

Statement of Responsibilities (SoR) and Management Responsibilities Map (MRM)

The SoR and MRM are the central SMCR documents. They are how the firm evidences what each Senior Manager is responsible for, and how responsibilities connect across the senior management team.

The Statement of Responsibilities

Every Senior Manager must have a current SoR that sets out:

The Senior Management Functions they perform
The Prescribed Responsibilities allocated to them
Other significant responsibilities they hold
The business areas, products, client groups or activities for which they have responsibility
Any shared responsibilities (subject to the PR rule that PRs cannot be shared)
Changes to the previous version, where the SoR is an update

The SoR is a regulatory document submitted to the FCA as part of the Senior Manager approval application. It must be kept current — when the Senior Manager’s responsibilities change, the SoR must be updated and resubmitted. Firms that do not maintain SoRs properly — stale documents, responsibilities that do not match what the individual actually does — are at material regulatory risk.

The Management Responsibilities Map

For Enhanced firms, a Management Responsibilities Map is required. The MRM:

Shows the full senior management structure
Identifies every Senior Manager and their SMFs
Maps all Prescribed Responsibilities and other significant responsibilities across the senior management team
Demonstrates that all business areas and activities have a named Senior Manager accountable for them
Identifies any gaps or unallocated responsibilities

The MRM is a comprehensive governance document that requires active maintenance. At large firms, MRMs can run to dozens of pages and involve complex matrix relationships between SMFs, business lines and support functions. Keeping the MRM current when people leave, join or change roles is a non-trivial ongoing workstream.

Duty of Responsibility — Personal Accountability

The Duty of Responsibility is the feature that most distinguishes SMCR from the former Approved Persons Regime. Under the Duty, if the firm contravenes a regulatory requirement in an area for which a Senior Manager is responsible, that Senior Manager can be personally held accountable unless they took reasonable steps to prevent or remedy the breach.

How the Duty operates

The Duty is not strict liability — Senior Managers are not automatically liable for every breach in their areas. But they are accountable for demonstrating they took reasonable steps. Where they cannot demonstrate reasonable steps, enforcement action can follow.

Reasonable steps typically include:

Understanding the risks in their area of responsibility
Setting appropriate policies, controls and governance
Ensuring adequate resources are deployed
Establishing effective reporting and monitoring
Responding appropriately when issues are identified
Documenting decisions and the basis for them
Escalating matters that warrant wider attention

The Duty applies alongside the Senior Conduct Rules, which impose positive standards on Senior Managers (including SC1: take reasonable steps to ensure the business is controlled effectively; SC2: ensure the business complies with regulatory requirements; SC3: take reasonable steps to ensure delegated responsibilities are discharged; SC4: disclose appropriately information of which the FCA would reasonably expect notice).

Enforcement under the Duty

The FCA has taken enforcement action against Senior Managers under the Duty of Responsibility and the related Senior Conduct Rules. Outcomes have included fines, prohibitions from performing SMFs, and public censure. Enforcement decision notices are published and provide useful guidance on the FCA’s approach to specific failings.

The existence of the Duty changes how senior compliance and risk roles are approached in UK financial services. Taking on an SMF is taking on personal regulatory liability — which is one reason the market for senior compliance and risk candidates is so tight, and why appropriate candidate due diligence matters on both sides of the recruitment process.

Fit and Proper — What the Test Requires

Both Senior Managers and Certified Persons must be fit and proper to perform their roles. The FCA’s Fit and Proper test assesses:

The three limbs of Fit and Proper

Honesty, integrity and reputation: Any criminal record, civil judgments, regulatory sanctions, previous dismissals for misconduct, pattern of customer complaints, and similar matters.
Competence and capability: Qualifications, experience, training, and demonstrated ability to perform the specific role. Competence is role-specific — competent to be MLRO is not the same as competent to be CFO.
Financial soundness: Personal financial standing, bankruptcy, IVA history, judgments for unpaid debts, and similar factors that could create conflict with the role.

Initial and ongoing assessment

Fit and Proper is not a one-off assessment at appointment. Firms must reassess periodically (at least annually for Certified Persons; continuously for Senior Managers) and act where circumstances change. Where a Senior Manager or Certified Person is no longer fit and proper, the firm must remove them from the role and notify the FCA where applicable. Getting this right requires robust HR, compliance and performance management processes working together.

Fit and Proper assessments in recruitment

When recruiting into SMF or certified roles, firms must satisfy themselves that the candidate meets the Fit and Proper standard before appointment. This involves background checks, reference checks (including Regulatory References — see below), reviewing the candidate’s FCA history, and in some cases specific qualification assessments. A recruitment process that places a candidate into an SMF role without adequate Fit and Proper due diligence is exposing the firm to regulatory risk.

Regulatory References — the Specific Employment Reference Regime

The Regulatory References regime is a specific SMCR requirement that affects how firms handle the recruitment of Senior Managers, Certified Persons and Non-Executive Directors.

What a regulatory reference contains

When recruiting into a role subject to the regime, the hiring firm must request a regulatory reference from the candidate’s previous employers for the past six years (or three years for NED-only roles, subject to specific thresholds). The outgoing firm must provide the reference using the prescribed FCA template, which includes:

Whether the individual performed any SMF, certified role or NED role at the previous firm
Whether the individual was subject to any disciplinary action for Conduct Rule breaches
Whether the individual’s fit and proper assessment resulted in any adverse findings
Whether there were any circumstances around the individual’s departure that the hiring firm should know about
Historical data from the relevant six-year period, not just the immediately preceding role

Why the regime matters

The regime was designed to prevent the “rolling bad apples” problem — individuals leaving one firm under a cloud and joining another without the new firm knowing. Under the regime, outgoing firms have a duty to disclose relevant information; hiring firms have a duty to request it. Firms that do not run the process properly — incomplete references, references not requested, known issues not disclosed — face supervisory and enforcement risk.

The practical implications for recruitment

For candidates moving between SMCR firms, the regulatory reference can be the decisive factor in the recruitment outcome. For hiring firms, running the reference process properly is a specific SMCR operational requirement that sits with HR and compliance working together. This is one of the areas where we help firms most frequently in our SMCR compliance recruitment work — placing candidates whose regulatory reference positions are clear, and guiding hiring firms on the reference process where there are any complexities.

The Certification Regime in Practice

Certification Regime operation is where many firms have struggled in practice. Unlike Senior Manager approval (which the FCA grants), certification is the firm’s own decision — but the firm is accountable for getting it right.

Identifying the certification population

Certified persons are employees other than Senior Managers who perform a “Certification Function” — a role the FCA specifies as capable of causing significant harm. The specific Certification Functions include:

Significant management function (individuals with significant responsibility for a business area not reaching SMF level)
CASS oversight function (for firms holding client money)
Proprietary trader function
Significant harm function (customer-facing roles where the potential for harm is significant)
Material risk taker (for firms subject to remuneration rules)
Client dealing function
Algorithmic trading function
Benchmark submission and administration functions (where applicable)

Identifying the certification population accurately is a specific exercise. Firms often find this harder than the Senior Manager identification because the certification population can run to hundreds or thousands of individuals at large firms, and role definitions change over time. Maintaining an accurate certification population register is an ongoing operational task.

The annual certification process

Every certified person must be certified annually by the firm as fit and proper. The process typically includes:

Self-assessment by the individual (disclosures, confirmation of ongoing fitness)
Line manager assessment (performance, conduct, any concerns)
Compliance and HR review (any outstanding issues, regulatory history, breach investigation outcomes)
Final certification decision (signed off at appropriate level)
Documentation and record keeping

Firms that treat certification as a tick-box exercise — forms signed without substantive review — are at regulatory risk. Substantive certification means taking positive steps to verify fitness, not merely confirming absence of adverse information.

The Conduct Rules and How They Apply

The Conduct Rules are the most broadly applicable part of SMCR, covering essentially all staff at in-scope firms. The implementation and ongoing management of the Conduct Rules is a significant operational area.

Who is subject to the Conduct Rules

The Individual Conduct Rules apply to:

All Senior Managers (plus the Senior Conduct Rules)
All certified persons
All other employees except those in specifically excluded roles (ancillary staff such as receptionists, catering, facilities management where the role has no connection to regulated activities)

In practice this means the vast majority of employees at in-scope firms are subject to the Conduct Rules. The population can run to tens of thousands at the largest firms.

Training on the Conduct Rules

Firms must train all in-scope staff on the Conduct Rules at appropriate intervals — initially on appointment, and refreshed periodically. Training must be tailored to role and seniority. Senior Manager training covers the Senior Conduct Rules; certified person training covers the Individual Conduct Rules in the context of their specific function; general staff training covers the Individual Conduct Rules at appropriate generality.

Quality of training is a supervisory focus area. Generic e-learning without role-specific content, training that is completed as a formality without engagement, or training that does not reflect the firm’s specific context and risks — all fall short of expectations.

Notifying Conduct Rule breaches

Firms must notify the FCA of any Conduct Rule breach that results in disciplinary action. The notification regime:

Senior Manager breaches resulting in disciplinary action: notified to the FCA within 7 business days
Other Conduct Rule breaches resulting in disciplinary action: notified annually

Firms must also maintain internal records of Conduct Rule breaches and the disciplinary outcomes. The FCA uses this data to identify patterns of concern, both at individual firms and across the industry.

Common SMCR Implementation and Ongoing Failings

Across the firms we see, certain SMCR failings recur. The FCA’s supervisory commentary on SMCR reinforces these patterns.

Stale Statements of Responsibilities

SoRs not updated when individuals’ responsibilities change. Documents that no longer reflect what the Senior Manager actually does. Unclear responsibility allocation that creates gaps or overlaps. All identified in FCA supervisory reviews as specific areas of concern.

Inadequate Prescribed Responsibility allocation

PRs allocated to individuals who do not have the authority or resources to discharge them. PRs allocated generically rather than to specific named individuals. PRs unallocated altogether. Each creates specific regulatory risk.

Weak certification processes

Certification decisions made without substantive assessment. Certification documentation that does not support the decision. Firms that cannot explain how certification decisions were reached. Pattern of automatic certification year after year without new information or assessment.

Poor Conduct Rules implementation

Inadequate training. Failure to notify breaches. Conduct Rule investigations that do not lead to appropriate action. Conduct Rule breach records that are incomplete or inaccurate.

Regulatory references not handled properly

References not requested for incoming appointments. Outgoing references that omit material information. Historical references for the full six-year period not obtained or retained. Reference requests processed too slowly, delaying appointments and exposing the hiring firm to gaps.

Over-reliance on the compliance function

SMCR is often treated as a compliance workstream when it should be a joint compliance-HR-line-management responsibility. Where compliance owns SMCR alone, implementation becomes theoretical rather than operational. Where HR is disengaged, certification and fit-and-proper suffer. Where line management is disengaged, Conduct Rule application falters.

Insufficient board engagement

SMCR is a board-level governance framework, but boards often receive only light reporting on it. Where SMCR is not a regular board agenda item, where Conduct Rule breach patterns are not reviewed by the board, and where the board does not substantively engage with the Senior Manager responsibilities framework, the regime operates below expected standards.

SMCR and Its Interaction With Consumer Duty and Other Regulations

SMCR does not operate in isolation. It sits alongside, and increasingly integrates with, the other major UK retail financial services regulations.

Consumer Duty

The Consumer Duty introduced new Prescribed Responsibilities and new Conduct Rules related to customer outcomes. Senior Managers now carry personal accountability for the firm’s performance on the four Consumer Duty outcomes within their areas of responsibility. See our Consumer Duty guide for detail on how the two regimes interact.

MLRO — SMF17 specifically

The MLRO role sits within SMCR as SMF17. The broader responsibilities of the MLRO are defined in the MLRs 2017 and POCA 2002 rather than SMCR itself, but the SMCR framework determines how the MLRO is held accountable. See our MLRO guide.

Operational resilience

The operational resilience regime assigns specific responsibilities that intersect with SMCR. Senior Managers hold personal accountability for operational resilience outcomes in their areas. Our forthcoming Operational Resilience guide will cover this interaction.

Regulatory reporting

The senior manager accountable for regulatory reporting (typically the CFO as SMF2, or a dedicated senior manager) carries SMCR responsibility for the firm’s reporting accuracy, timeliness and quality. See our Regulatory Reporting guide for more.

The Specialist Roles Firms Need for SMCR Operation

SMCR requires specific senior and specialist roles to operate effectively. The recruitment market for these roles is consistently active.

Chief Compliance Officer (SMF16)

Holds overall responsibility for the compliance function including SMCR. Typically the individual with primary operational ownership of the firm’s SMCR framework. See our Chief Compliance Officer recruitment page.

Head of SMCR / SMCR Manager

Specialist role responsible for day-to-day SMCR operation — managing SoRs, running the certification cycle, coordinating regulatory references, maintaining MRMs (at Enhanced firms), and acting as the internal reference point for SMCR queries. Typically reports to the CCO.

Conduct Rules training specialist

Roles focused specifically on Conduct Rules training programme design, delivery and effectiveness measurement. At larger firms this may be a dedicated role; at smaller firms it may be combined with broader compliance training responsibilities.

HR leadership in SMCR

HR plays a substantial SMCR role through recruitment (fit and proper at onboarding), performance management (ongoing fit and proper), regulatory references (incoming and outgoing), and disciplinary processes (Conduct Rule investigations). Senior HR leaders at FCA-regulated firms need specific SMCR understanding.

Legal leadership

SMCR enforcement risk, regulatory investigations, and disputes around Conduct Rule breaches all require specialist legal input. Firms typically combine internal legal resource with external specialist legal advice on SMCR matters.

Chief Risk Officer (SMF4)

The Chief Risk Officer carries SMF4 personal accountability. The CRO’s Statement of Responsibilities, Prescribed Responsibilities and relationship with the board on risk matters are all core SMCR considerations.

How FD Capital Places Senior Managers, Compliance and Risk Leaders

FD Capital operates a specialist FCA-regulated firms recruitment practice. Within this, SMCR-facing roles — SMF holders, compliance leadership, risk leadership, and the specialist functions around them — are among our most active placement areas.

Placement coverage

We place into:

Chief Executive Officer (SMF1), Chief Financial Officer (SMF2), Executive Director (SMF3), Chief Risk Officer (SMF4), Head of Internal Audit (SMF5), Chief Operations (SMF24) roles at UK FCA-regulated firms.
Compliance Oversight (SMF16) and MLRO (SMF17) roles — see our SMCR compliance recruitment and MLRO recruitment pages.
Chair (SMF9), Committee Chairs (SMF10/11/12/13), Senior Independent Director (SMF14) non-executive roles.
Specialist supporting roles — Head of SMCR, Conduct Rules training, SMCR managers, regulatory references specialists.

Candidate due diligence

Our placement process for SMF roles includes specific SMCR-relevant due diligence — regulatory history, reference positions, SoR coverage across prior roles, prescribed responsibilities experience. This reduces the risk for hiring firms of candidate issues emerging during the FCA approval process or after appointment.

Engagement models

We place permanent SMF appointments, interim and fractional SMF cover (where the regulatory position permits), and specialist supporting roles (Head of SMCR, certification managers) on permanent and interim bases.

SMCR is a Permanent Discipline — Staff the Right People for It

The firms that handle SMCR well recognise it as an ongoing operational discipline, not a compliance initiative to be implemented and forgotten. They invest in the right Senior Managers, the right specialist supporting roles, and the right governance around the framework. They review and refresh SoRs actively, they run substantive certification processes, they treat Conduct Rule training as a capability-building exercise rather than a compliance formality, and they handle regulatory references with the care the regime requires.

Firms that under-invest in SMCR typically find out they have done so when something goes wrong — a supervisory finding, a Conduct Rule investigation, an enforcement case, or the sudden departure of a Senior Manager creating a gap that is difficult to fill quickly. The cost of getting it right up front is materially less than the cost of remediation later.

FD Capital can help you find the right Senior Manager, Chief Compliance Officer, MLRO, Chief Risk Officer, Head of SMCR or specialist compliance support — permanent, interim or fractional — matched to your specific firm context and SMCR needs.

A Note from Our Founder — Adrian Lawrence FCA

The conversations I have about SMCR appointments fall into two broad categories. The first is firms recruiting into a specific SMF seat — CFO, CRO, CCO, MLRO — where the regulatory specifics of the role and the candidate’s fit for it are the substance of the search. The second is firms where something has gone wrong with SMCR operation — a supervisory finding, an enforcement concern, an individual departure exposing a gap — and the hiring decision carries weight beyond the single role. In both cases, getting the match right matters more than with non-SMF roles.

The candidates who succeed in SMF roles are typically those who understand that taking on a Senior Management Function means taking on personal regulatory accountability. They ask questions about their Statement of Responsibilities, they want to see how Prescribed Responsibilities are allocated, they want to know how the firm supports Senior Managers in discharging their responsibilities, and they will walk away from roles where the answers are unsatisfactory. Firms that understand this and engage properly get better candidates; firms that treat SMF recruitment as generic executive search get weaker ones.

At FD Capital we place SMF holders, compliance leaders, risk leaders and the specialist supporting roles that make SMCR work across UK FCA-regulated firms. If you are recruiting into a Senior Management Function, assessing your SMCR arrangements, or concerned about a specific role or transition, I am happy to have a direct conversation. Every mandate I take on is handled personally.

Hire a Senior Manager, Compliance Leader or Risk Leader for Your FCA-Regulated Firm

SMF appointments, Chief Compliance Officer and Chief Risk Officer placements, Head of SMCR and certification managers, NED and Chair appointments — all with the specific SMCR fit and due diligence required. FD Capital places Senior Managers and specialist SMCR support roles at UK FCA-regulated firms, as fractional, interim or permanent appointments.

Call: 020 3287 9501
Email: recruitment@fdcapital.co.uk

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SMCR Explained: The Senior Managers & Certification Regime — Complete UK Guide