CP17/40: Individual accountability: Transitioning FCA firms and individuals to the Senior Managers & Certification Regime

Open consultation: CP17/40
Consultation closes
Policy Statement
Summer 2018
Summer 2018

We consulted on how FSMA ​​​​​authorised firms and individuals will move to the Senior Managers and Certification Regime.

CP17/40: Individual accountability (PDF)

The Senior Managers and Certification Regime aims to make individuals more accountable for their conduct and competence. Earlier this year, we consulted on how the regime will apply to firms and individuals. This consultation paper focuses on how we will move firms and their senior staff over to the new the regime.

We’re calling this process ‘conversion’, and our aim is to make it simple, clear and proportionate. For the majority of firms, we are planning to automatically convert Approved Persons Regime (APR) approvals to Senior Management Functions. This means the majority of firms won’t need to submit anything to the FCA to make this happen.


We’ve proposed different approaches to moving firms to the new regime based on whether a firm is categorised as limited scope, core or enhanced. We recommend checking your firm category before reading the consultation paper. You can do this by using the firm checker tool on page 3 of the consultation paper.

Jonathan Davidson on extending the Senior Managers and Certification Regime

This video gives an overview of SM&CR and our plans for moving firms to the regime.

The consultation paper sets out the detailed proposals for all types of firms. This includes transitional provisions to give firms time adapt to the new regime.

Who this applies to

The proposals in this consultation relate to all firms authorised by us under FSMA, except for:

The proposals in this consultation do not extend to approved persons and individuals at Appointed Representatives of affected firms.

Consumers may be interested how individual accountability is being enhanced within financial services. 

Next steps

This consultation has now closed. We will consider your feedback and aim to publish a summary of responses and a policy statement in 2018.