SMCR for FCA-solo regulated firms
By extending the SMCR to all FSMA authorised firms, the FCA is changing the individual accountability regime for firms as diverse as large asset managers, mortgage providers and investment firms through to crowdfunding platforms, consumer credit firms and sole traders.
To take account of the differences in terms of size, complexity and potential impact on consumers or markets, the FCA has proposed a three tiered regime, which distinguishes between “core firms” which will be subject to a standard set of SMCR requirements; “enhanced firms” whose size, complexity and potential impact warrant the application of extra requirements, and “limited scope” firms which will be subject to a reduced set of requirements.
Please see our Linklaters Insights for more information on the FCA's proposals.
Extended SMCR publications
| Consultation papers and discussion papers | Policy statements |
| July 2020 FCA consultation paper (CP20/10) on extending implementation deadlines for the Certification Regime and Conduct Rules until 31 March 2021. |
October 2020
FCA policy statement (PS/20/12) on extending the implementation deadlines for the Certification Regime and Conduct Rules until 31 March 2021. |
| July 2020 PRA consultation paper (CP7/20) proposing minor amendments to forms relating to the SMCR. |
Consultation closes on 13 October 2020 |
| November 2019 FCA consultation paper (CP19/31) on extending the SMR to Benchmark Administrators |
June 2020 FCA policy statement (PS20/5) on extending the SMR to benchmark administrators who do not undertake any other regulated activities. |
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January 2019
FCA consultation paper (CP19/4) on optimising the SMCR and feedback to DP16/4 (overall responsibility and the legal function) |
July 2019
FCA policy statement (PS19/20) on optimising the SMCR – feedback to CP19/4 and final rules |
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October 2018
FCA (GC18/4): Proposed guidance on statements of responsibilities and responsibilities maps for FCA firms |
March 2019
FCA (FG19/2): on statements of responsibilities and responsibilities maps for FCA firms |
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September 2018
FCA consultation paper (CP18/26) on how the FCA propose to apply the SMCR to claims management companies |
March 2019
FCA policy statement (PS19/9) on applying the Senior Managers and Certification Regime to Claims Management Companies
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July 2018
FCA consultation paper (CP18/19): Introducing the Directory |
March 2019
FCA policy statement (PS19/7) on the Directory |
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December 2017
FCA consultation paper (CP17/40) on individual accountability: Transitioning FCA firms and individuals to the SMCR
FCA consultation paper (CP17/42) on the duty of responsibility for insurers and FCA solo-regulated firms |
July 2018 FCA policy statement (PS18/14): Extending the SMCR to FCA firms – feedback to CP17/25 and CP17/40, and near-final rules, with accompanying Guide for FCA solo-regulated firms FCA policy statement (PS18/16) with final guidance on the duty of responsibility for insurers and FCA solo-regulated firms |
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November 2017
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July 2018 FCA policy statement (PS18/18) on industry codes of conduct and discussion paper on FCA principle 5. Includes final criteria for recognising industry codes of conduct and guidance for individuals on meeting rule 5 of the Conduct Rules |
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July 2017 |
July 2018 |
