FCA and PRA streamline SM&CR requirements
UK financial firms must update SM&CR certification, senior-manager filing and enhanced-firm threshold controls
Change
The FCA and PRA streamlined SM&CR requirements by reducing overlapping certification roles, raising enhanced-firm thresholds by 30%, and giving firms up to 12 weeks to submit senior manager applications after unexpected or temporary changes.
Why it matters
The reforms change the operating scope of SM&CR compliance while keeping senior-manager accountability in place. Firms must update certification mapping, enhanced-firm classification, fit-and-proper checks, criminal-record-check validity, senior-manager application workflows, responsibilities updates and directory-update processes to match the revised regime.
Implications
- — SM&CR compliance teams at UK financial firms must update certification mapping to remove overlapping certification functions and reflect the reduced certification-role scope.
- — Regulatory affairs and HR teams must revise senior-manager application workflows so unexpected or temporary changes use the new 12-week submission window.
- — Compliance teams at firms near enhanced-SM&CR thresholds must reassess firm classification against the revised thresholds raised by 30%.
- — Fit-and-proper and onboarding teams must update annual certification checks, criminal-record-check validity controls and directory-update timelines under the FCA/PRA reforms.
- — Senior-management responsibility-map owners must update reporting processes for changes to senior manager responsibilities within the revised timelines.
Who is affected
- — SM&CR compliance owners at UK financial firms
- — Regulatory affairs teams handling senior-manager applications
- — HR and onboarding teams handling fit-and-proper checks
- — Enhanced-SM&CR firm classification teams
- — Senior manager responsibility-map owners
What to watch
- — FCA and PRA reform date: April 22, 2026
- — Policy statements: FCA PS26/6 and PRA PS12/26
- — Senior manager application window: up to 12 weeks after unexpected or temporary change
- — Certification impact: around 15% reduction in certification roles
- — Enhanced-firm thresholds: many thresholds raised by 30%
- — Future phase: Government proposals to remove the Certification Regime from legislation and reduce SMF pre-approval burden