Senior Managers & Certification Regime (SMCR) in 2026

How we got to the SMCR Regime

• Senior managers and certification regime training begins by explroing regulator expectations
• Aims and Objectives of SMCR
• Regime Categorisation – Core vs Enhanced

Senior Managers Regime

• SMF categories
• Prescribed responsibilities
• Statement of Responsibilities (SoR)
• Exercise – Reviewing the SoR
• Duty of responsibility (collective vs. individual obligations)
• Management Responsibility Maps
• Defining Reasonable Steps
• Case Study – Reviewing Reasonable Steps for an SMF

Certification Regime

• Significant harm functions – who is in scope?
• What am I certifying?
• Assessing competency: measuring with consistency
• When to assess Fitness & Propriety
• Regulatory references – obligations and liabilities

Conduct Rules

• Individual conduct rules: what they are and how they apply
• Non-financial misconduct – effective September 2026 completes this section of SMCR conduct rules training

Breach Reporting

• What constitutes a breach? Which breaches matter?
• Are all disciplinary issues automatically conduct rule breaches?
• FCA Breach reporting obligations
• Exercise – an overheard conversation suggests a breach of conduct rules, which is challenged and escalated – who behaves appropriately in the ongoing discussions? (Includes SMFs, Certified Persons and Conduct Rules staff)

What we can Learn From the Implementation So Far

• Key lessons from SMCR implementation and regulatory experience to date
• Case Study – Jes Staley, Former CEO, Barclays
• Common themes emerging from enforcement and supervisory activity
• Understanding 'Reasonable Steps' and its growing role in regulatory investigations, including the FCA's ‘Dear CEO’ letters on overdraft arrangements, concludes training on senior management and certification regime

Involved with SMCR and its rollout to banking firms since 2016, SMCR conduct rules training is delivered by a specialist who shares the challenges he encountered and practical lessons he learned that remain relevant across regulated firms.

With over 30 years of experience in the financial services sector, he specialises in regulatory and financial crime compliance. Previously serving as the Head of Education for HSBC covering the UK and Europe, he was responsible for compliance learning during the bank’s Deferred Prosecution Agreement. This expert's career includes tenures at Barclays within the Private Clients and Wealth functions, as well as a Senior Vice President role at a major US-based bank, where they led Global Risk & Compliance training.

Highly knowledgeable about the senior manager & certification regime, he brings significant technical expertise from time spent at the Financial Conduct Authority in the Insurance Firms division. Whilst here, he served as the divisional expert on the rules and outcomes under the Training & Competence handbook. This trainer’s background in the second line of defence includes leading the Monitoring and Testing programme for a prominent UK Wealth Manager, who was provided with a comprehensive insight into practical application compliance frameworks.

With a delivery style informed by his extensive experience across retail, commercial, wholesale and private banking channels, this trainer has a proven collaborative track record. He’s worked with compliance, HR, and operational teams, enhancing regulatory understanding across private equity firms, investment houses, and wealth managers. A former member of the Investment Management Association Training & Education Committee delivers Senior Managers and Certification Regime training. This expert was also the recipient of the 2010 Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm”.

• SMCR training courses articulate the regulatory intent: explain the FCA’s strategic goals of accountability and transparency
• Accurately Categorise Personnel: identify and distinguish between Senior Manager Functions (SMFs), Certified Persons (CPs), and Conduct Rules staff
• Operationalise Accountability: draft and manage Statements of Responsibilities (SoR) and understand the "Duty of Responsibility"
• Embed Conduct Standards: apply individual and senior manager conduct rules to real-world scenarios to foster a compliant firm culture
• Manage Compliance Cycles: implement effective processes for fitness and propriety assessments, regulatory references, and breach reporting in this SMCR conduct rules training

Senior Managers and Certification Regime Training is ideal for:

• Senior Manager Functions (SMFs): individuals holding high-level responsibilities within their firms
• Certified Persons (CPs): team members whose roles may cause "significant harm" to the firm or its customers
• Oversight & Control Functions: essential for Risk, Compliance, HR, and Company Secretariat professionals

Originally rolled out to the banking sector in 2016, the Senior Managers and Certification Regime (SMCR) has now been extended to over 40,000 firms.

The Financial Conduct Authority (FCA) tightened its rules, replacing the Approved Persons Regime with SMCR. This change affected all FCA-regulated firms, including non-UK firms with permission to carry out regulated activities in the UK, and focuses on three key areas:

1. The Senior Managers Regime
2. The Certification Regime
3. Conduct Rules

2026 sees changes to the regime and clearer guidance on non-financial misconduct. All aspects of SMCR conduct rules training can be customised for the specific operating models of your team.