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Buckingham Capital Consulting Ltd  |   One Kingdom Street, London, W2 6BD  |  Telephone: 0800 689 0501  |   Email:

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Senior Managers and Certification Regime (SM&CR)

Senior Managers and Certification Regime

The Senior Managers and Certification Regime (SM&CR) replaces the Approved Persons Regime, changing how people in financial services are regulated.

The Senior Managers and Certification Regime (SM&CR) has been developed by the Financial Conduct Authority in response to the 2008 banking crisis and significant failings within financial services, such as LIBOR manipulation. The aim of SMCR is to develop a framework of accountability for senior management. It aims to raise conduct standards at all levels within financial services firms.

There are 3 key parts to the Senior Managers and Certification Regime:

  • the Senior Managers Regime

  • the Certification Regime

  • conduct Rules

Senior people or ‘senior managers’, performing key roles are required to seek FCA approval prior to commencing their roles. Firms are required to assign a number of specific responsibilities to their ‘senior managers’ to ensure the presence of a senior manager, accountable for the Senior Managers and Certification Regime. 

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What is the aim of the Senior Managers and Certification Regime (SM&CR)?

The Senior Managers and Certification Regime (SM&CR) aims to reduce harm to consumer whilst strengthening market integrity. It attempts to achieve this by holding individuals more accountable for their conduct and competence.

The aims of the Senior Managers and Certification Regime (SM&CR) are:

  • To encourage a culture of staff responsibility

  • To ensure that staff and firms understand and demonstrate responsibility.


Who does the Senior Managers and Certification Regime (SM&CR) apply to?

The SM&CR regime applies nearly all FCA regulated firms, ranging from consumer credit to investment firms. It will apply to all FSMA authorised firms as well as to branches of non-UK firms.


How does the Senior Managers and Certification Regime (SM&CR) apply?

  • Core: firms in this tier will have to comply with the requirements.

  • Enhanced: this will apply to a small number of firms whose size, complexity and potential impact on consumers or markets warrant more attention. These firms will have extra requirements.

  • Limited scope: this will apply to firms who already have exemptions under the Approved Persons Regime. These firms will be exempt from some requirements and have fewer senior management functions.

How Buckingham Capital Consulting can help


We can help firms with the following:

  • Determining tier under which a firm falls under

  • Allocating responsibility to senior managers

  • Management responsibility mapping

  • Preparation of policies and procedures

  • SMCR training and education

  • FCA response management

Next Steps

Buckingham Capital Consulting is a leading international consulting firm, specialising in payment services, electronic money, banking and investment services. We are able to advise you on the best course of action and strategy based upon your business plan and financial product or service. We can help you with licencing, compliance, operational setup and related services, including, obtaining banking facilities.


Call us today on 02078662512 or 442078662512 if you are calling from abroad. You can send an email to to arrange a telephone call or to discuss your requirements and plan. We are also able to arrange calls or conference calls using Skype. Our Skype ID is BCC54321. If you wish, we can arrange a meeting at one of our offices.