FCA Senior Managers Regime Guidance Clarifies SMF Approval, Accountability, and Fitness Requirements
The FCA's updated Senior Managers Regime guidance restates that Senior Management Function (SMF) holders need regulatory approval before starting their roles, must have a Statement of Responsibilities, and carry a statutory Duty of Responsibility. Requirements differ by firm type (solo- or dual-regulated) and category, so compliance teams should confirm that their categorization, responsibility allocation, and fitness and propriety processes align with the guidance. Senior individuals face personal accountability if reasonable steps are not taken to prevent or stop breaches.


