Bank of England and UK Financial Conduct Authority propose accountability reforms expected to save firms GBP 2 billion

The Bank of England’s Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) have launched parallel consultations on proposals to narrow senior appointment approval requirements and remove the Certification Regime for around 139,000 individuals below senior manager level. The proposed changes to the Senior Managers and Certification Regime (SM&CR) are expected to save firms around GBP 2 billion over 10 years while preserving individual accountability. This second phase follows April 2026 reforms that increased flexibility for senior manager applications, removed overlapping certification requirements and raised thresholds for enhanced firms. Appointments to roles including chief actuaries and chairs of risk and audit committees would move from prior regulatory approval to notification, with firms responsible for assessing candidates’ fitness and propriety. Chief executives, chief financial officers and chairs would still require approval, and regulators could require approval for otherwise notified roles in high-risk cases. The proposals would also remove annual certification and associated register requirements for the affected staff, raise the conduct rule breach reporting threshold for most staff below senior manager level and streamline conduct rule training. Firms would remain responsible for employee competence, suitability and conduct, with accountability unchanged for roles moving to notification. The reforms are expected to reduce PRA SM&CR pre-approvals by 43% and halve the overall burden of its regime. Some proposals depend on legislative changes, and policy is expected to follow in 2027.