The Financial Conduct Authority (FCA) and the Bank of England’s Prudential Regulation Authority (PRA) have published a first package of reforms to the Senior Managers and Certification Regime (SM&CR) intended to reduce compliance costs and increase flexibility while maintaining the core principle of senior leader accountability. The changes include giving firms up to 12 weeks to submit a senior manager application following an unexpected or temporary change, removing the need to certify individuals across multiple overlapping functions which is expected to reduce certification roles by around 15%, and streamlining annual ‘fit and proper’ certification checks. Enhanced SM&CR standards are narrowed by raising many enhanced firm thresholds by 30%, alongside additional clarifications on certain senior management roles, more time to report changes to senior manager responsibilities, longer validity for criminal record checks prior to application submission, and more time to update the directory of certified staff. The FCA reported 99.7% of applications determined within the current three-month statutory deadline (94.7% within the proposed two-month deadline), while the PRA reported 100% within three months (98% within two months). HM Treasury’s consultation response sets out further potential legislative changes, including removing the Certification Regime from legislation and giving regulators greater flexibility to reduce the number of senior management functions requiring pre-approval. The FCA and PRA plan to consult later in the year on wider reforms that could be enabled by any additional legislative freedom, as part of the Leeds reforms to halve the SM&CR’s regulatory burden on firms.
Bank of England 2026-04-22
Bank of England and Financial Conduct Authority set out phase one reforms to streamline the Senior Managers and Certification Regime
The Financial Conduct Authority and the Bank of England’s Prudential Regulation Authority have issued initial Senior Managers and Certification Regime reforms to lower compliance costs and increase flexibility while preserving senior manager accountability. Measures include extended timelines for applications and reporting, reduced overlap in certification functions, narrowed enhanced firm scope through higher thresholds, and streamlined “fit and proper” checks. HM Treasury’s consultation response outlines potential legislative changes to remove the Certification Regime from statute and give regulators more discretion over pre-approval functions, with further consultations on broader reforms planned.