Senior Managers & Certification Regime (SM&CR).
Practical support to help firms implement, maintain, and evidence compliance with SM&CR requirements.
SM&CR is more than a regulatory framework, it is a fundamental shift in accountability across financial services. Designed to reduce consumer harm and strengthen market integrity, SM&CR makes it easier for both firms and regulators to hold individuals directly responsible for their actions.
Covering senior managers, certified staff, and conduct rules staff across the organisation, the regime demands that firms embed a culture of accountability, transparency, and ethical decision-making.
DOCUMENTED & DEMONSTRABLE ACCOUNTABILITY.
Our SM&CR experts work with you to ensure the regime is fully embedded within your business. We provide practical, regulator-ready support that strengthens governance, mitigates risk, and ensures your firm can demonstrate compliance with confidence.
Having supported a wide range of authorised firms, we know the nuances of implementing, reviewing, and maintaining SM&CR obligations. Whether you need a full framework review, remediation support, or tailored Conduct Rules training, we provide solutions that are commercially focused, regulator-aligned, and tailored to your firm’s needs.
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REVIEW
We assess your existing SM&CR policies, procedures, and documentation from Statements of Responsibilities and Management Responsibility Maps to Fitness & Propriety assessments and Conduct Rules training records. Our detailed feedback identifies weaknesses and gaps that could leave you exposed to regulatory challenge.
REMEDIATION
Once risks are identified, we provide hands-on support to address them. This may include updating documentation, enhancing breach reporting processes, supporting Fitness & Propriety assessments, preparing Form A applications, and delivering Conduct Rules training tailored to your firm’s operations.
REINFORCEMENT
Embedding SM&CR requires ongoing reinforcement. We provide interactive, scenario-based training to ensure staff understand their Conduct Rules obligations, backed by practical materials for use across your intranet or e-learning systems.
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FREQUENTLY ASKED QUESTIONS
Find answers to the questions we’re asked most often, from our compliance and training services to how we can support your business.
What is SM&CR and who does it apply to?
The Senior Managers and Certification Regime (SM&CR) is an FCA regulatory framework designed to strengthen individual accountability across financial services. It applies to all FCA-regulated firms and covers senior managers, certified staff, and conduct rules staff, making it easier for firms and regulators to hold individuals directly responsible for their actions.
What are the key obligations under SM&CR?
Under SM&CR, firms must identify and map senior management responsibilities, ensure senior managers are fit and proper, certify relevant staff annually, and embed conduct rules across the organisation. Firms must also maintain accurate and up-to-date regulatory references and ensure all relevant staff have received appropriate Conduct Rules training.
What are the consequences of poor SM&CR compliance?
Poor SM&CR compliance can result in FCA enforcement action against both the firm and individual senior managers. The regime is specifically designed to ensure that individuals can be held personally accountable for regulatory failures, making robust SM&CR implementation a critical priority for all regulated firms.
How should firms embed SM&CR into their culture and governance?
Effective SM&CR implementation goes beyond documentation to embed a genuine culture of accountability, transparency, and ethical decision-making across the organisation. This requires clear responsibility mapping, regular Conduct Rules training, robust certification processes, and board-level oversight of SM&CR obligations.
How can Cosegic help with SM&CR implementation and compliance?
Cosegic provides practical, regulator-ready SM&CR support tailored to each firm's specific needs. Whether you require a full framework review, remediation support, or tailored Conduct Rules training, our experts ensure SM&CR is fully embedded within your business, strengthening governance and enabling you to demonstrate compliance with confidence.