About a-team Marketing Services
The knowledge platform for the financial technology industry
The knowledge platform for the financial technology industry

A-Team Insight Blogs

FCA Publishes Final Rules on SM&CR

Subscribe to our newsletter

The UK financial services regulator has published the final rules regarding the extension of the Senior Managers and Certification Regime (SM&CR) to FCA solo-regulated firms. The changes are due to come into force on December 9, 2019 – the same deadline by which brokers have to comply with the new regulation (which was adopted by banks in 2016 and insurance firms in 2018).

The changes include the exclusion of the Head of Legal function from the requirement to be approved as a Senior Manager, a clarification of the requirements and scope of the certification regime, and an extension of the Senior Manager Conduct Rule 4 (SC4) to non-approved Executive Directors at Limited Scope firms.

The extension follows a consultation by the FCA launched in January 2019, for which it reportedly received just 29 responses.

The regulator has previously urged brokers to ensure they are ready for the new regime, which will substantially increase personal accountability among the directors of affected firms, of which there are an estimated 47,000 in the UK.

“’The one key piece [of advice] which I would absolutely leave with somebody else who is adopting it is – this has got to be owned and led by the business, so you cannot delegate it to HR or compliance or any other kind of function,” warned Vis Raghavan, Chief Executive Officer of EMEA, J.P. Morgan earlier this year.

The complexity of the regulation is such that firms are being forced to turn towards technology – meaning that a multitude of new solutions are now emerging to assist with the new requirements.

“For firms of a certain size, the complexity and scale of managing SM&CR means technology is the only workable solution. The risk to the firm, and individually to senior managers, of personal fines and sanctions, is too significant to rely on manual solutions,” says Redland Solutions, a regtech software firm.

“The cost and pace of regulatory change is cited by many Chief Risk Officers and Chief Compliance Officers as one of the biggest and highest priority risks in the industry and there are no signs of it reducing. The degree of regulatory change, if anything is set to increase.”

Subscribe to our newsletter

Related content

WEBINAR

Upcoming Webinar: Hearing from the Experts: AI Governance Best Practices

9 September 2025 10:00am ET | 3:00pm London | 4:00pm CET Duration: 50 Minutes The rapid spread of artificial intelligence in the financial industry presents data teams with novel challenges. AI’s ability to harvest and utilize vast amounts of data has raised concerns about the privacy and security of sensitive proprietary data and the ethical...

BLOG

CFTC Outlines New Framework for Self-Reporting and Cooperation in Enforcement Cases

The U.S. Commodity Futures Trading Commission (CFTC) has issued new guidance on how it will evaluate self-reporting, cooperation, and remediation efforts when considering enforcement actions, marking a significant shift in how firms and individuals can approach regulatory violations—see CFTC Release Number 9054-25. For the first time, the CFTC’s Division of Enforcement has introduced a Mitigation...

EVENT

AI in Capital Markets Summit New York

The AI in Capital Markets Summit will explore current and emerging trends in AI, the potential of Generative AI and LLMs and how AI can be applied for efficiencies and business value across a number of use cases, in the front and back office of financial institutions. The agenda will explore the risks and challenges of adopting AI and the foundational technologies and data management capabilities that underpin successful deployment.

GUIDE

AI in Capital Markets: Practical Insight for a Transforming Industry – Free Handbook

AI is no longer on the horizon – it’s embedded in the infrastructure of modern capital markets. But separating real impact from inflated promises requires a grounded, practical understanding. The AI in Capital Markets Handbook 2025 provides exactly that. Designed for data-driven professionals across the trade life-cycle, compliance, infrastructure, and strategy, this handbook goes beyond...