UK regulators final policy on reforms to the SMCR

The UK Financial Conduct Authority (FCA) and UK Prudential Regulation Authority (PRA) have published final policy statements (FCA PS26/6 and PRA PS12/26) on Phase 1 reforms to the Senior Managers and Certification Regime (SMCR). The reforms largely implement proposals as consulted on in July 2025. For more detail on the reforms, you may wish to read our blog post titled UK Senior Managers and Certification Regime overhaul: understanding proposals for reform.

The FCA's reforms focus on streamlining administrative requirements and include greater flexibility around the 12‑week rule (allowing firms 12 weeks to submit, rather than obtain approval for, Senior Management Function (SMF) applications), extended validity periods for criminal record checks, simplified requirements for statements of responsibilities and management responsibilities maps (with firms given up to six months to notify changes), removal of overlapping multiple certifications within the Certification Regime, updated guidance on Fit and Proper recertification, extended deadlines for updating the Directory (from seven to 20 business days), and raising certain enhanced firm thresholds by 30%.

The PRA's policy statement introduces parallel Phase 1 reforms for PRA‑authorised firms, with a stronger prudential focus, including refinements and clarifications to SMFs (notably SMF7), changes to supervisory expectations and notifications (including use of Form L), and alignment with the revised 12 week rule for temporary or unexpected changes in senior management.

The majority of FCA and PRA rule changes take effect on 24 April with certain FCA process and reporting changes applying from 10 July. In addition, FCA changes aligning with its policy on non‑financial misconduct in financial services will take effect from 1 September. Both regulators note that more significant Phase 2 reforms, which are dependent on legislative change (see HMT's consultation response covered separately), are expected to be consulted on later in the year.

Return to main website.