SM&CR Reforms: What’s Changed?

The Financial Conduct Authority (FCA) has published Policy Statement PS26/6, confirming the first phase of changes to the Senior Managers & Certification Regime (SM&CR).

The aim is to make SM&CR easier to operate while maintaining clear individual accountability.

Most changes came into force on 24 April 2026, with further updates due in July and September.

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What’s changed now?

Several practical updates are already in place.

Criminal records checks are now valid for six months instead of three.

Firms do not need to repeat criminal records checks for internal or intragroup SMF moves where appropriate checks have already been carried out.

Firms now have 12 weeks to submit SMF applications rather than needing approval within that timeframe.

Individuals can remain in role while approval is pending, with Senior Manager Conduct Rules applying during this period.

Overall, these changes make recruitment and internal moves more straightforward.

More flexibility in responsibilities

There is now greater flexibility in how firms manage responsibilities and documentation.

There is clearer guidance on allocating and, where appropriate, splitting Prescribed Responsibilities.

Firms have more flexibility when updating Statements of Responsibilities and Management Responsibilities Maps.

In many cases, firms have up to six months to notify changes, and where multiple updates occur, only the most recent version needs to be submitted.

This reduces reporting burden, but firms still need to maintain accurate and up-to-date internal records.

Changes to the Certification Regime

The Certification Regime has been streamlined to better reflect how firms operate.

Firms can issue digital certificates.

Certification can be aligned with annual appraisal cycles.

A more proportionate approach can be taken where there have been no material changes.

Firms must still be able to demonstrate that individuals remain fit and proper.

What’s coming next

Further changes are expected later in 2026.

These include higher thresholds for firms to fall within the Enhanced SM&CR category, the removal of some overlapping certification roles, and more time to update Directory information.

The FCA has also indicated that it intends to consult on a second phase of reforms, subject to legislative change.

What this means for firms

The changes introduce more flexibility but do not reduce core expectations.

Accountability remains unchanged.

Firms should ensure responsibilities are clearly defined, governance remains robust, and decisions can be clearly evidenced.

Next steps

Now is a good time to review SM&CR frameworks and identify where processes can be simplified without weakening control.

If you are reviewing your SM&CR framework following PS26/6, or want to understand where you can simplify without increasing risk, contact B-Compliant to discuss how these changes apply to your firm.