SM&CR: Form K explained

Form K is the conversion notification form. It enables firms to tell us which approved individuals they wish to convert from the Approved Persons Regime (APR) to corresponding Senior Management Functions (SMFs) under the Senior Managers & Certification Regime (SM&CR).

Form K must be submitted by 23.59pm on 24 November 2019.


Who needs to submit Form K?

Enhanced firms must submit a Form K which has been available on our Connect system since 9 September 2019.

Core firms with a Non-Executive Chair (currently approved as a CF2) will need to submit Form K to convert that individual to an SMF9 (Chair) under the SM&CR.

If a Core firm has CF2s but none of these individuals perform the role of a non-executive Chair, no Form K is required.

More information by firm category can be found below.

How to submit Form K

For information on how to submit Form K, see our step-by-step user guides:

Once you have a Form K in draft, you cannot start a new one – you must edit the Form K you already have in draft.

If you need to make changes to your Form K after submitting it, you cannot edit it. You can, however, submit a new Form K, but this will involve starting the notification again.

If you decide not to convert an individual to the SM&CR using Form K, in most cases no Form C is required. Form C is only required if a decision is made not to convert an individual due to changes in their fitness and propriety.

If you have an Approved Person Form A/Form C/Form E application in progress you need to include this person on your Form K. This individual will show in your Form K as ‘applied for’. You must ensure you select the required SMF to map to, otherwise this person will not be approved post Commencement. If the individual does not show as ‘applied for’ please contact us.

If you have completed an Approved Person Form A/Form C/Form E since starting your Form K, when you log back into Connect a ‘Recalculate’ button will appear at the top of the Conversion Notification section of the form. Once you’ve clicked this button, any changes you’ve made to your approved persons will be reflected in your Form K. If you try to submit your Form K without refreshing the form, an error message will appear prompting you to click the button.

Form K is only used to convert approved persons (including ones that are pending a decision) to Senior Management Functions (SMFs). If you have applied for someone to hold a SMF directly using the SM&CR Form A, they will not be included in Form K.

More information by category

Enhanced firms

Form K will list all individuals at the firm who are currently approved by the FCA and highlight what Senior Management Function/s (SMFs) they may map across to.

You should select the SMF(s) each individual will map to under the SM&CR, by clicking the relevant box. 

You can select multiple SMFs per individual if applicable.

Form K will generate a summary of your selections by listing the individuals that have been selected to map to SMFs, and will also list the individuals (if any) whose regulatory approval will not convert across to the new regime. 

A Statement of Responsibilities (SoR) must be completed for each Senior Manager being converted as part of the Form K notification.  Once you have selected all of the currently approved individuals that you wish to map across as Senior Managers under the SM&CR, the system will then generate a SoR for each Senior Manager as a related application. All SoRs must be completed before you can submit your Form K.

You also need to attach a Management Responsibilities Map within your Form K. This is mandatory and your Form K cannot be submitted without it.

Core firms with a CF2 who is converting to SMF9 (Chair)

Form K will only list the CF2s (Non-Executive Directors) at your firm.

If any of your CF2s perform the role of the SMF9 (Chair), you should select this within Form K.

Form K will generate a summary of your selections by listing the individual/s that have been selected to convert to SMF9.

If you have other CF2s at your firm not mapping to SMF9 they will be listed to show that their regulatory approval will not convert across to the new regime.

All other approved individuals at your firm will not show in Form K. Instead, where there is a corresponding SMF, they will be automatically converted.

You do not need to attach a Management Responsibilities Map within your Form K as this is only a requirement for Enhanced firms. Only Enhanced firms need to submit Statement of Responsibilities (SoRs) to us as part of their Form K. However, Core firms must still ensure every Senior Manager has a SoR by 9 December 2019. After that date, you must be able to provide a Senior Manager’s SoR to us on request.