Senior Managers & Certification Regime (SMCR) in 2026

How we got to the SMCR regime

• 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. How can I measure this consistently?
• When to assess Fitness & Propriety
• Regulatory references – obligations and liabilities

Conduct Rules

• Individual conduct rules: what are they and how do they apply
• Non-financial misconduct – effective September 2026

Breach Reporting

• What constitutes a breach? Which breaches matter?
• Are all disciplinary issues automatically conduct rule breaches?
• Breach reporting obligations to the FCA
• Exercise – an overheard conversation suggests a conduct rule breach, 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

• What we can learn from experience to date
• Case Study – Jes Staley, CEO, Barclays
• Reasonable Steps – increasingly common in general regulatory requests, e.g. the Dear CEO Letter regarding overdraft arrangements

Our trainer has been involved with SMCR since 2016 and the roll-out to banking firms. He can share the challenges faced and lessons learned for all regulated firms.

He has over 30 years of experience within the financial services sector, specialising in regulatory and financial crime compliance. He previously served as the Head of Education for HSBC, covering the UK and Europe, where he was responsible for compliance learning during the bank’s Deferred Prosecution Agreement. His 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, leading Global Risk & Compliance training.

He brings significant technical expertise from his time at the Financial Conduct Authority (formerly the FSA) in the Insurance Firms division. During this period, he served as the divisional expert for the rules and outcomes required under the Training & Competence handbook. Additionally, his background in the second line of defence includes leading the Monitoring and Testing programme for a prominent UK Wealth Manager, providing him with a comprehensive view of the practical application of compliance frameworks.

Our trainer’s delivery style is informed by his extensive experience working across retail, commercial, wholesale, and private banking channels. He has a proven track record of collaborating with compliance, HR, and operational teams to enhance regulatory understanding across private equity firms, investment houses, and wealth managers. A former member of the Investment Management Association Training & Education Committee, he was also the recipient of the 2010 Thomson Reuters award for “Most Effective Compliance Training at a Regulated Firm”.

• 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

• Senior Manager Functions (SMFs): Individuals holding high-level responsibilities within their firms
• Certified Persons (CPs): Staff 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 up its rules, replacing the Approved Persons Regime with the Senior Managers and Certification Regime (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 covered in our course which can be customised to address your specific operating models.