The FCA has been focusing on driving individual accountability and cultural change in recent years, particularly through the introduction of the Senior Managers and Certification Regime (SMCR) which currently applies to banks, building societies, credit unions and dual regulated investment firms.

SMCR will come into force for financial services firms regulated by the Financial Conduct Authority (FCA) only (also known as solo-regulated firms) beginning December 9, 2019.

We have created an SMCR toolkit which gives firms access to a range of key documents that are needed in order to implement the SMCR in their business. It includes

  • A project plan, which maps progress against deadlines
  • A template management responsibilities map
  • Tools to map senior managers to their new functions
  • Tools to identify certified staff and map/identify the prescribed responsibilities and overall responsibilities across the business to their senior manager function holders
  • Template statement of responsibilities and drafting guides
  • Employment law-related documentation including clause banks to amend employment contracts
  • A confidentiality and non-disclosure agreement for senior managers
  • An outline of the impact of the regime on the employee lifecycle

The toolkit comes with legal and compliance support should that be required. We can also provide a fully comprehensive set of training packages.

The SMCR is aimed at changing behaviours and culture in the financial services sector. It ensures that senior individuals in firms are approved by the regulator, have a statement of responsibilities outlining what they are accountable for, and can be held personally responsible for misconduct. It also ensures that all financial services staff can be held to appropriate standards of conduct, and that employees in roles where they could do significant harm to consumers or to the UK’s financial stability are approved annually by their firm. The FCA wants to see genuine engagement by firms.


Global Head of Financial Services
Head of Employment - Europe, Middle East and Asia
Co-Head of the Contentious Financial Services Group, London
Global Director of Financial Services Knowledge, Innovation and Product