SMCR: 10 things all FCA solo-regulated financial services firms need to know

Our briefing note highlights the top 10 things you need to know about the proposed extension of the Senior Managers and Certification Regime (SMCR) to all FCA solo-regulated financial services firms.

Please note that there is a slightly different regime for insurers on which the FCA and PRA are consulting. Please see here for more details.


The FCA has now published more detailed proposals on the implementation of the regime. Further information is available here.

In this briefing note, we answer the following ten questions:

  1. When will the extended regime apply to FCA solo-regulated financial services firm?
  2. What are the main elements of the SMCR?
  3. Will there be different requirements for different types of FCA solo-regulated firm?
  4. How do I know whether my firm is a Core SMCR Firm or an Enhanced SMCR Firm?
  5. What are the differences between the extended SMCR regime and the current SMCR regime which already applies to banks?
  6. How does the extended regime apply if my firm is structured as a partnership?
  7. Are there any specified Senior Manager positions which must be filled and/or specific responsibilities which must be allocated?
  8. What is the “Duty of Responsibility” for Senior Managers?
  9. What is the territorial applicability of the regime? What if my firm is a branch of an overseas firm?
  10. What should I be doing now?

Download the briefing note

For more information on the SMCR Extension please see our microsite

This document (and any information accessed through links in this document) is provided for information purposes only and does not constitute legal advice. Professional legal advice should be obtained before taking or refraining from any action as a result of the contents of this document.