The FCA are reviewing their Senior Managers & Certification Regime framework - Discussion Paper DP1/23 was part of the review – to understand if it’s working in practice.

Following early feedback to DP1/23, firms were pretty aligned: SM&CR is doing its job, but some of the practical bits (approvals, certification, and general admin) were feeling a bit… clunky. ‍

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So, what’s the plan?

Fast forward through last year’s Consultation Paper (CP25/21) which proposed fixes, and we now have the FCA’s latest update in Policy Statement PS26/6, in which those fixes have been finalised.

And the headline is: this is a step in the right direction.

Many of the changes are designed to ease the day-to-day burden of running SM&CR, with some already in force as of 24 April 2026.

Here’s what’s changing, and what firms should be doing now and next. ‍

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What’s changing? Phase 1 - live from 24 April 2026.

A mix of quick wins and practical tweaks:

Criminal record checks (for new SMF applications)
These are now valid for 6 months instead of 3. It’s a small change, but a helpful one when timelines slip. But heads up, forms may take a little while to catch up.

‍The 12-week rule
Previously, firms needed approval within 12 weeks for temporary or unexpected SMF cover. Now, you’ve got 12 weeks to submit the application instead, which creates less pressure.

Regulatory references
The turnaround time has been reduced from 6 weeks to 4 weeks. Quicker responses enable smoother hiring processes.

Certified staff
Some welcome simplification here:

• Clearer guidance on Fit & Proper assessments  

• These can now be aligned with annual appraisals  

• More time to update the Financial Services Register after changes  

SMF roles and responsibilities
The FCA has added:

• Clearer guidance on when SMF roles apply  

• More flexibility when allocating or splitting Prescribed Responsibilities  

• A longer window (6 months) to notify the FCA of changes  ‍

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‍What’s changing? Phase 2 (coming 10 July 2026)

A couple more structural tweaks to be aware of:

Prescribed Responsibilities
For solo-regulated firms, SMF18 (Other Overall Responsibility) holders can now take on any Prescribed Responsibilities. This should make role allocation more flexible.

Certification Regime
Some overlapping roles are being removed, helping to simplify certification mapping.

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What’s next?

The FCA isn’t stopping here; they’ve confirmed they’re continuing to improve:

• The SMF application process  

• The speed of approvals  

• And the overall usability of forms  

All things we won’t complain about. ‍

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What should firms be doing now?

This isn’t a ‘drop everything’ moment, but is a good opportunity to sense-check your current processes.

At Verve, we’re already updating a few things in line with the new rules:

• Templates  

• Internal documentation  

• The way we support firms through SM&CR  

If you want to talk through what this actually means in practice, or where you can make life a bit easier, just shout.  

Book a chat or drop us a line, and your usual consultant (or any of the team) will happily help.

If you’re here to solve questions your compliance provider can’t answer, we recommend downloading our Adviser’s Guide to Switching Compliance Services – it helps outline compliance red flags, what to do about them, and how everything could change in 12 weeks with our free compliance switching service.

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