The Senior Manager and Certification Regime (SMCR) is a cornerstone of UK regulation. It is the UK’s response to plug gaps in the regulation of financial services that would in future enable regulators to hold individuals to account when things go wrong.


The application of SMCR has been gradually extended across the financial services sector since its first introduction in 2016. Firms having to implement the regime first time benefit from the lessons learned by those who had to implement earlier. Many existing SMCR firms are also now looking to make material improvements or benchmark their implementation against industry best practice.


This guide brings together best practice, relevant regulations and, roles and responsibilities in a practical framework that you can use to self assess your own framework, select sections and turn them into internal policies and procedures. The guide explains the multiple different SMCR firm types, the relevant regulations and most importantly tells you what you need to do to implement the regime.


When implementing any regulation a certain tolerance has to be set for regulatory risk. In this framework that regulatory risk tolerance is set for businesses wanting to show they are taking SMCR seriously and doing the right thing in their firm based on real regulatory and compliance advisory experience of what other firms are actually doing as best practice, and what both the PRA and FCA have said they expect.


The guide covers:

  • Key messages to use internally
  • What to include in your policies and procedures
  • The common pitfalls to avoid
  • The current and historic rules, and guidance
  • Regulatory notifications
  • An SMCR checklist


The guide is written succinctly and has the crispness expected in wholesale firms whilst getting to the point. The main document is 19 pages long, as it carefully covers each of the three component regimes, the fit and proper test and provides context and background to the regime.


The six-page SMCR checklist is included as an annex and also available for digital download as an Excel sheet. The guide avoids use of regulatory jargon and legal terminology, but includes definitions of the key terms used when referring to the SMCR.


We also provide a number of SMCR training packs as a digital download that supports implementation of this guide.

How to Comply with the SMCR


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