Information on SMCR breaches reported by firms - September 2025

Overall number of reports of changes to fitness and propriety over the 5-year period: 2,158.

Data limitations:

• The FCA does not have any internal categorisations to this data.
• Data includes reports received via three different forms:
• Short Form A: used to apply for a Senior Manager application where the candidate was previously approved within the last 6 month. This form is not designed for firms to notify the FCA of changes of fitness and propriety - if there has been a change, firms should use a Long Form A instead. Nevertheless, some firms have indicated a change to fitness and propriety via Short Form As. It is not possible to complete a manual review of these applications to assess the relevance of the reason firms have indicated a change in fitness and propriety within the cost limitation.
• Form D: used to notify of changes to circumstances, including changes to fitness and propriety. This can include breaches of Conduct Rules as well as changes of fitness and propriety which are not considered a breach of Conduct Rules. Due to the way the data is stored, the figures include Senior Managers under the Senior Manager Regime and Approved Persons under the Approved Persons Regime (in relation to Appointed Representatives). It is not possible (within the cost limitation) to complete a manual review of the cases to assess the relevance of the reason firms have notified of a change in fitness and propriety.  
• Form C: used to notify when individuals cease to perform controlled functions, including Senior Manager functions. The notifications included have already been manually review and categorised as a qualified withdrawal – meaning that the FCA considers the information contained may affect our assessment of fitness and propriety if an application is received for the individual in future. Due to the way the information is recorded, it has been possible to remove notifications regarding Appointed Representatives, so this data relates only to Senior Managers.
• Data in respect of Short Form As has been received from solo-regulated firms (i.e., firms regulated only by the FCA and not by both the FCA and the PRA).  
• Data in respect of Form Ds and Form Cs has been received by both solo-regulated firms and dual-regulated firms (firms regulated by both the FCA and PRA). 

• REP008 means the breach of conduct was reported by a firm regarding a conduct rules member of staff. These are reported annually. This is much larger population compared to Approved Persons and explains why breach reporting volumes for this question are significantly higher than the number of changes to fitness & propriety recorded under question 1).
• Form C&D mean the breach was reported by a firm regarding a Senior Manager Function holder. These are reported shortly after the breach occurred.
• Due to limitations in data, we have had to use calendar years rather than the year end dates requested.
• Where a breach report lists that more than one rule was broken by an individual, they are counted once (e.g. if the misconduct constituted a breach of rules 2 and 4, they would only be counted once)
• Where an individual has been reported at more than one entity (e.g. because they are a group employee linked to two regulated firms), they are counted once for each entity
• A very small proportion of these reports will not be reports of new breaches, but updates on a previous year’s report. E.g. where someone appealed a dismissal to the Employment Tribunal, or that someone has internally appealed the disciplinary action and the outcome.

We are not able to provide data for 2025 as not all returns have been provided for the year.

Regarding the breakdown by types of misconduct reports received using the FCA’s internal categorisation, the FCA does not have any internal categorisation for this data.