Navigate SM&CR with Confidence
Establish accountability, strengthen governance, and meet FCA expectations.
The Senior Managers & Certification Regime (SM&CR) applies to all Financial Services and Markets Act (FSMA)-authorized firms and aims to strengthen market integrity by increasing individual accountability. It replaces the Approved Persons Regime and comprises three core components:
- Senior Managers Regime
- Certification Regime
- Conduct Rules
While the Conduct Rules apply broadly, the SM&CR target individuals in key roles. The FCA and Prudential Regulation Authority (PRA) continue to evolve the framework to reduce regulatory burden while maintaining high standards.
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Embed Accountability and Strengthen Your Compliance Framework
We’ve supported a wide range of firms—solo- and dual-regulated—with implementing and embedding SM&CR. Our services are designed to ensure your framework is robust, compliant, and ready for regulatory scrutiny.
SM&CR Framework Review
Remediation Support
Training
Let’s Strengthen Your SM&CR Framework
Technology-Enabled Oversight
SM&CR isn’t just about policies, it’s about proving oversight. ACA’s ComplianceAlpha® platform empowers firms to meet their accountability obligations with data-driven surveillance and behavioral analytics. Key capabilities include:
Cross-market Manipulation Detection
Insider Trading Detection
Entity-level Risk Assessment
Trader Behavior Profiling
Personal Account (PA) Dealing and Data Integration
Stay Ahead of Reform
With proposed changes to SM&CR underway, including streamlining the senior manager function (SMF) approval process, reforming the Certification Regime, and raising thresholds for Enhanced Firms, our specialists help you stay proactive. Key reform highlights:
Simplified 12-Week Rule Guidance
Extended CRC Validity
Reduced Form a Documentation
Periodic Statement of Responsibility (SoR) Updates
Increased Thresholds for Enhanced Firms
Choose ACA to Strengthen Oversight and Simplify Compliance
Trusted by firms across the regulatory spectrum, ACA delivers tailored solutions that evolve with your needs.
Regulatory Expertise with Scalable Technology
From implementation to ongoing oversight, ACA helps firms operationalize accountability and streamline compliance.
Trusted by a Broad Range of Firms
Proven track record supporting solo- and dual-regulated firms across the financial services landscape.
Tailored, Practical Support Through Change
Proportionate solutions designed around your firm’s needs, with ongoing guidance through regulatory reform.
FAQs
What is the Senior Managers & Certification Regime (SM&CR)?
SM&CR is a UK regulatory framework designed to increase individual accountability and strengthen governance across FSMA-authorised firms.
What are the key components of SM&CR?
The regime includes three core elements: the Senior Managers Regime, the Certification Regime, and the Conduct Rules.
- Senior Managers Regime: Requires firms to assign clear responsibilities to senior individuals and ensure they are accountable for their areas of oversight.
- Certification Regime: Applies to individuals who aren’t senior managers but perform roles that can cause significant harm; firms must certify their fitness and propriety annually.
- Conduct Rules: A set of behavioral standards that apply to most staff, designed to promote integrity, fair treatment of customers, and proper market conduct.
Who does SM&CR apply to?
SM&CR applies to all FSMA-authorized firms, including solo- and dual-regulated entities, and affects senior managers, certification staff, and most employees through the Conduct Rules.
How can ACA help firms implement SM&CR?
ACA offers framework reviews, remediation support, tailored training, and technology solutions to help firms embed SM&CR and meet FCA expectations.
What does an SM&CR framework review involve?
ACA reviews Statements of Responsibilities, Management Responsibility Maps, Fitness and Propriety assessments, Conduct Rules training, and more to identify gaps and ensure compliance.
What training does ACA provide for SM&CR and Conduct Rules?
ACA’s FCA training program delivers annual update sessions, role-specific Conduct Rules training, compliance inductions, and workshops for certification staff, Compliance Officers, and MLROs.
How does ACA’s ComplianceAlpha® platform support SM&CR?
ComplianceAlpha enables firms to monitor conduct, detect market abuse, assess entity-level risk, and integrate personal account dealing data to support oversight and certification.
What are the latest proposed changes to SM&CR?
Reforms include streamlining the senior manager function (SMF) approval process, updating SoR submission rules, reforming the Certification Regime, and raising thresholds for Enhanced Firms.
Why choose ACA for SM&CR support?
ACA combines deep regulatory expertise with scalable technology, offering tailored solutions for firms navigating SM&CR obligations and regulatory change.
What should I do if I want to explore ACA’s SM&CR support further?
Request a strategy session to connect with ACA’s SM&CR specialists and discover how we can help strengthen your governance framework and meet regulatory expectations.
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