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The Financial Conduct Authority (FCA) has confirmed the next steps for changes to the Senior Managers & Certification Regime (SM&CR), including updates to the Certification Regime and Directory.
The changes are part of the FCA’s Phase 1 reforms to make the SM&CR more efficient and proportionate, while maintaining strong individual accountability.
Most SM&CR changes took effect on 24 April 2026. Further improvements to regulatory reporting and processes will apply from 10 July 2026, including the removal of duplication in the Certification Regime. From that date, firms will no longer need to certify the same individual to perform multiple overlapping certification functions.
The FCA has confirmed that it will remove the duplicate roles from the Directory itself. This is now expected to take place on 30 July 2026.
As a result, duplicate roles may remain visible on the Directory for a short period between 10 July and 30 July. Firms are not expected to take any action to address those duplications during that period.
Members should continue to notify the FCA of any other changes to their Directory Persons data in the usual way.
The Phase 1 reforms also cover areas including criminal record checks and disclosure, the 12-week rule, Statements of Responsibilities, regulatory references, Conduct Rules, prescribed responsibilities and thresholds for becoming an enhanced SM&CR firm.
Further changes linked to PS25/23, covering non-financial misconduct in financial services, will apply from 1 September 2026. The FCA also expects to consult on a second phase of broader SM&CR reforms later in 2026, subject to proposed Treasury changes progressing.
Members should review FCA Policy Statement PS26/6 for full details and check whether any internal SM&CR processes need updating ahead of 10 July. Dual-regulated firms should also review the PRA’s accompanying Policy Statement (published in July 2025).
