CP26/37: Senior Managers and Certification Regime (SM&CR) Review: Phase 2

The FCA is consulting on simplifying SM&CR following the FSM Bill's transfer of more rulemaking discretion to regulators. For compliance teams, the direction of travel is fewer prescribed Senior Management Function applications, more notified roles, a streamlined approval process, a narrower Enhanced regime, and reduced ongoing Statements submissions. This should lower administrative burden for many firms, but it does not relax accountability expectations.

Firms should map current SMF populations and Statements arrangements against proposed removals and notification routes; model whether higher Enhanced-regime thresholds change their status; and review governance documentation, job descriptions, and delegation records so revised allocations remain clear. Consultation response and implementation planning should be coordinated with HR, legal, risk, and company secretarial teams. Medium urgency: no immediate rule change, but early gap analysis will help firms avoid last-minute repapering and ensure regulatory references, fitness and propriety, and conduct-rule training remain robust.

RegCanary recommends monitoring final rules and PS26/6 sequencing.