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Support with the Senior Managers and Certification Regime (SM&CR): getting senior managers approved by the Financial Conduct Authority (FCA), allocating responsibilities, running certification and keeping pace with the 2026 reforms.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
The short answer
The Senior Managers and Certification Regime (SM&CR) requires FCA authorised firms to have each senior manager approved by the FCA before they start, give each one a written statement of responsibilities, certify staff in significant roles as fit and proper every year, and train staff on the Conduct Rules. An SM&CR consultant prepares Form A applications, maps responsibilities, builds certification processes and tests that the firm can evidence accountability.
SM&CR applies to banks, insurers and firms authorised by the FCA under the Financial Services and Markets Act 2000 (FSMA), including consumer credit, investment, insurance broking and mortgage firms. It has three parts.
How much of SM&CR applies depends on the firm's category, and getting the category right is the first step of any implementation. Limited scope firms, such as many limited permission consumer credit firms, have a reduced set of SMFs. Core firms have the baseline regime, typically including the chief executive, chair, executive director, compliance oversight and MLRO functions. Enhanced firms, the largest and most complex, also need a management responsibilities map, prescribed responsibilities spread across senior managers and handover procedures.
The FCA's 2026 reforms raised the financial thresholds for enhanced status by 30 per cent to reflect inflation, so some firms that were enhanced can now operate as core firms. SUP 10C Annex 1 in the FCA Handbook sets out which functions apply to each type of firm. We confirm your category, list the functions and prescribed responsibilities that apply, and identify any role that is missing or held by the wrong person.
Most SM&CR work starts with an approval. The firm applies on Form A through the FCA's Connect system, with a statement of responsibilities, a criminal records check and regulatory references from previous employers where required. The FCA must decide within three months of receiving the application. Its own figures for the third quarter of 2025/26 show 99.7 per cent of applications decided within that limit.
Applications are slowed by avoidable gaps: unclear responsibilities, incomplete employment histories, missing references and weak answers on the candidate's knowledge of the firm. Where the FCA interviews a candidate, the questions test whether they understand the firm's risks, rules and controls in their own area. We prepare the application and statement of responsibilities, check every disclosure for consistency with the FCA register and prepare candidates for interview. Since PS26/6, criminal records checks stay valid for longer before submission, and firms have up to 12 weeks to submit an application where a role must be covered unexpectedly.
Certification is where most firms fall behind, because it relies on the firm's own records rather than an FCA decision. Each certified person needs a documented fit and proper assessment covering honesty, competence and financial soundness, at the start and at least annually. The 2026 reforms reduced duplication, so one person no longer needs certifying for several overlapping functions, and clarified that a proportionate annual assessment is acceptable where nothing material has changed.
Firms must also train staff on the Conduct Rules, notify the FCA of breaches that lead to disciplinary action, keep the FCA's Directory of certified and assessed persons current, and give regulatory references when asked. Under PS26/6, firms now have four weeks rather than six to respond to a reference request. We build the annual certification cycle into your human resources calendar, write the assessment templates and train managers to run them.
The FCA and the Prudential Regulation Authority (PRA) confirmed phase 1 SM&CR reforms on 22 April 2026. The FCA's PS26/6 took effect mainly from 24 April 2026, with reporting and process changes from 10 July 2026 and changes linked to non-financial misconduct from 1 September 2026. HM Treasury has said it will legislate to remove the Certification Regime from statute and reduce the number of roles needing pre-approval.
On 22 October 2026 the FCA published CP26/37, its phase 2 consultation, which closes on 22 January 2027. It proposes removing the Certification Regime, cutting the number of SMF applications by removing some functions and turning others into notified roles, streamlining the application process, raising thresholds so fewer firms are enhanced, and retiring the Directory. We track each stage so your arrangements stay compliant today and are ready for the new framework, without rebuilding them twice.
Payment institutions (PIs) and e-money institutions (EMIs) are authorised under the Payment Services Regulations 2017 (PSRs) and the Electronic Money Regulations 2011 (EMRs), not under the FSMA permission regime, so SM&CR does not apply to them. The FCA still assesses their directors and the people responsible for managing payment services or e-money at authorisation, and changes to those individuals must be notified.
Cryptoasset businesses registered with the FCA under the Money Laundering Regulations 2017 (MLRs) are also outside SM&CR today, but the planned UK cryptoasset authorisation regime will bring authorised crypto firms within FSMA. For groups that hold both kinds of licence, such as an EMI alongside an investment or consumer credit firm, we design one governance structure that meets both sets of rules, so the same people are not assessed against conflicting role descriptions.
Every engagement follows the same four stages, scaled to the size of your firm and the urgency of the issue.
Assessment: we review your firm category, governance map, statements of responsibilities, certification records, Conduct Rules training and Directory entries against SUP 10C, SYSC 24 to 27 and COCON. Written findings: you receive a report showing what is complete, what is missing and which items carry regulatory risk, ranked by priority. Remediation: we redraft statements of responsibilities and responsibilities maps, prepare Form A applications, build certification templates and run Conduct Rules training. Ongoing support or outsourced roles: we provide an annual SM&CR health check, support each new approval, and can act in compliance oversight or MLRO roles where your firm needs them.
Buckingham Capital Consulting (BCC) was established in 2013 and has obtained more than 250 licences in over 60 countries for payment, e-money and crypto firms. That licensing work means we have seen, from the application stage onwards, the controls, people and documents regulators expect to find when they test a firm after authorisation.
We do not stop at the licence. BCC also arranges banking and runs compliance for regulated firms, so the advice you receive reflects how a regulated business actually operates day to day: how its bank partners review it, how its regulator supervises it and how its own board needs to evidence control. Our aim is set out in one line: we open global markets to payment, e-money and crypto businesses, with the licences to enter, the banking to operate and the compliance to scale. If you are weighing your options, use the contact form to describe your firm and the issue, and we will reply with a proposed scope.
The FCA must decide on a complete senior manager application within three months of receiving it. Its published figures show most applications are decided well inside that limit, and the phase 1 reforms consulted on a two month deadline. Gaps such as missing regulatory references or an out of date criminal records check are the most common causes of delay.
Form A is the FCA application for approval of a person to perform a senior management function. It is submitted through Connect and includes the candidate's employment history, fitness and propriety disclosures, criminal records check details and a statement of responsibilities. A shorter version applies to some candidates who have held an approved role recently.
Not yet. HM Treasury has said it will remove the Certification Regime from primary legislation when parliamentary time allows, and the FCA's CP26/37, published on 22 October 2026, proposes removing it from FCA rules. Until the law and rules change, firms must keep certifying staff annually.
Under PS26/6, where a firm must replace a senior manager unexpectedly, it now has up to 12 weeks to submit the approval application, rather than having to obtain approval within 12 weeks. The person covering the role can continue while the application is pending, and the Senior Manager Conduct Rules apply to them.
No. They are authorised under the Payment Services Regulations 2017 or Electronic Money Regulations 2011, so SM&CR does not apply. The FCA still assesses their directors and managers at authorisation, expects good governance, and requires them to notify changes in the people who run the firm.
It involves confirming whether the firm is limited scope, core or enhanced, identifying each senior management function and prescribed responsibility, drafting statements of responsibilities, applying for approvals, identifying certified roles and running fit and proper assessments, training staff on the Conduct Rules and updating the FCA Directory.
Tell us what you need and where you operate.