What you need to know about the Senior Managers and Certification Regime

Making individuals more accountable 

The Senior Managers and Certification Regime (SMCR) was extended to cover all FCA solo-regulated firms in December 2019. The overarching goal of the regime is to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence.

This means firms must have identified and nominated individuals to formally perform their Senior Manager Roles. Once Senior Manager Roles have been established, firms must maintain up-to-date records of their responsibilities and performance. These individuals must also undergo an annual assessment to ensure their ‘fitness and propriety’.

Understanding how responsibilities and roles are divided among the Senior Managers of a firm is not just important for the Senior Managers themselves, who have personal liability, but for the firm as a whole.

Since the introduction of SMCR, similar regulations have been developed in other regulatory jurisdictions.


While some firms are still grappling with the initial implications of SMCR and defining their roles and responsibilities, others are beginning to focus on the implementation of the ongoing monitoring and record keeping aspect, which remains an issue.

Increased scrutiny

Recent economic crises have only increased the scrutiny on how Senior Managers can evidence their steps to perform their duty and meet their conduct obligations. This includes understanding who the key workers in their team are, maintaining essential customer services, and ensuring appropriate product governance.

While most firms have managed the initial implications of SMCR and defined their roles and responsibilities, many are continuing to struggle with implementation of the ongoing monitoring and record keeping aspect, which is key to be able to demonstrate the firm’s compliance with SMCR.

Ensuring compliance with the SMCR regime continues to be a pressing issue for many firms

SteelEye reduces the complexity and cost of financial compliance and provides clients with a centralised data platform for monitoring and managing Senior Manager Responsibilities and Roles. SteelEye is also equipped with automatic triggers and alerts to remind firms to define new roles and to address the requirement for an ongoing annual assessment of fitness and propriety of each senior manager. Book a demo to learn more about how SteelEye can help you Comply Smarter™.

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