Senior Managers And
Certification Regime

The Financial Conduct Authority (FCA) introduced the Senior Managers & Certification Regime (SM&CR) for all FCA regulated firms in December of 2019. The Regime represented a significant change to these firms and requires resources and planning to implement effectively.

Forming part of the FCA’s Culture and Governance priority, SM&CR aims to promote the development of a ‘culture of accountability at all levels within FCA regulated firms.

There are three categories of FCA regulated firms  

  • Limited Scope,
  • Core and
  • Enhanced.

SM&CR applies each of these categories in varying ways and must adhere to the rules that apply in respect of each category.

Replacing the FCA’s Approved Persons Regime, FCA authorised firms are no longer able to apply ‘Control Functions’ but must instead appoint Senior Management Functions (SMFs). These functions are typically held by the most senior people within a firm. This forms part of the Senior Managers element of SM&CR.

Why do some firms hold Limited Permissions and others don’t?

The Certification Regime (CR), the second element of SM&CR, requires that firms determine whether they are required to appoint a Certification Function.

The appointment of a Senior Management Function and/or Certification Function may only occur where the appointment satisfies fitness and propriety requirements and in the case of SMFs, where the appointment has been approved by the FCA. Certification Functions are approved by firms internally as opposed to the FCA. Certification functions should therefore be assessed and if found to be appropriate, issued a certificate that is valid for a maximum of 12 months. The ongoing fitness and propriety of both SMFs and CRs must be assessed annually as a minimum.

Appointed Representatives and Principal Firms

SMFs must have Statements of Responsibility. Depending upon a firm’s category e.g., Core firm, Statements of Responsibility will also have mandatory Prescribed Responsibilities (PR), which will be split amongst relevant SMFs or held by just one. This enables the FCA to identify who is accountable for a responsibility. PRs would not apply to Limited Scope firms.

For all categories of firms, there are Conduct Rules that must be adhered to. These are a set of minimum standards of individual behaviour and applies to all Senior Managers, Certification Functions, Non-executive Directors who are not SMFs and all other employees apart from ancillary staff.

There are two tiers of conduct rules i.e., Individual Conduct Rules and Senior Management Conduct Rules. Firms should seek to understand how the Conduct Rules are understood in the context of roles and responsibilities and ensure relevant individuals are appropriately trained.

FCA Authorisation

If you are looking to become authorised by the FCA, MEMA can help.

Each applicant who works with MEMA is assigned a dedicated Regulatory Adviser who will support you throughout your application, answering queries you may have relating to the application and providing you with guidance and support.

The process starts with a fact find between yourself and one of our Regulatory Advisors where we’ll get to know you and your business and how you intend to provide your services.

We will provide you with advice and guidance on how to comply with the FCA’s requirements and identify any risks.

We will then produce for you a series of documents to support your application and help ensure that you become authorised. These documents include a Regulatory Business Plan and Compliance Monitoring Plan. We also produce a compliance manual for you containing documentation for you to implement into your business upon authorisation to help enable you to comply with the FCA’s requirements.

An online application will then be completed along with all relevant forms, which will then be submitted to the FCA. Should there be any FCA questions, your Regulatory Adviser will work with you to draft a full response.

In short, we’re here for our clients every step of the way. We provide our clients with the benefit of our knowledge and experience to not only help ensure that your application is successful, but that your business has the right foundations to ensure positive customer outcomes.

Ongoing FCA Compliance

As an FCA authorised person or firm, you might need help to ensure you comply with the FCA’s rules.

We provide our clients with support they need to maintain compliance and avoid breaching the rules. Our bespoke service is individually tailored to each of our client’s requirements and objectives to help them meet in the best way possible.

Whether you need documentation to help you remain compliant, want ongoing advice or support, impartial monitoring of your activities or anything else, MEMA may be able to help.

Why Choose MEMA?

Get started!

MEMA has been supporting firms through the FCA compliance process since 2019. In that time, we have helped hundreds of businesses to successfully gain and retain FCA authorisation.

We have a unique blend of experience from ex-regulators, big 4 consultants and fin/regtech specialisation. Our team is highly experienced and expertly skilled. We specialise in providing our clients with solutions to often complex regulatory requirements and compliance needs.

Our unique industry insight and comfort with compliance enables our team to support you to the fullest extent possible, helping to develop your business model and compliance.

Contact us

July 28, 2021

Anti Money Laundering warnings

The Financial Conduct Authority (FCA) issued a warning to retail banks in May 2021 (made public on 29 June) over continued weaknesses and failings surrounding their financial crime controls.

More about us

April 11, 2021

FCA Cryptocurrency Regulation Part 1

From 10 January 2020, the FCA became the anti-money laundering and counter-terrorist financing (AML/CTF) supervisor for crypto firms, covering firms that exchange money to and from crypto assets and those that safeguard their customers crypto assets.

More about us

August 9, 2023

Revised U.K. Financial Regulators' Complaints Scheme - Coming into effect 1, November 2023

In a collaborative effort, the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), and Bank of England have unveiled their revised Complaints Scheme, which fundamentally shapes the protocol for addressing and managing grievances lodged against the U.K. regulatory bodies. This revamped framework encompasses several significant modifications:

More about us

Insights

November 23, 2022

FCA's new rules on Appointed Representative Regime

Changes to the Appointed Representatives regimes will take effect from 08 December 2022. The final rules were published in the Financial Conduct Authority’s policy statement to improve the appointed representative's regime.
More about us
December 19, 2022

What is the Senior Managers & Certification Regime ?

The Senior Managers and Certification Regime (SM&CR) replaces the Approved Persons Regime (APR) which is how the FCA used to regulate people working in financial services.
More about us
January 31, 2022

New restrictions on the financial promotions of crypto assets

The Financial Conduct Authority (FCA) has launched a consultation paper (CP22/2) on financial promotion rules for high-risk investments, including crypto assets.
More about us
April 25, 2022

What to take away from the FCA's Business Plan 2022-2023

The FCA has released its new business strategy for the next 12 months.
More about us
April 11, 2021

Preparing for your annual FCA Reporting Requirements

Your firm is due to submit its regulatory return(s) within 30 business days of your Accounting Reference Date. Reporting requirements apply to all firms with permissions to carry on regulated claims management activities, including firms with temporary permissions.
More about us
August 29, 2022

Who would be considered a Politically Exposed Person (PEP)?

“A Politically Exposed Person (PEP) is a natural person who is or has been entrusted with prominent public functions and includes his/her immediate family or persons known to be close associates of such persons, but shall NOT include middle ranking or more junior officials.”
More about us
March 7, 2025

Navigating the UK Crypto Landscape: Key Definitions and Regulatory Overview

The United Kingdom has a rapidly evolving crypto market with growing consumer interest. Yet, despite increased adoption, many crypto businesses and investors remain uncertain about the rules governing this space.
More about us
February 21, 2025

Financial Promotions Under Scrutiny: FCA Doubles Down on Compliance Enforcement

The financial services landscape is witnessing unprecedented regulatory scrutiny, with the Financial Conduct Authority (FCA) significantly intensifying its oversight of financial promotions. In a striking development, nearly 20,000 financial promotions were withdrawn or amended in 2024—representing a dramatic doubling of regulatory interventions compared to the previous year.
More about us
January 7, 2022

FCA Fee Cap on CMCs

You will be aware that the FCA’s price cap is coming into existence on 1 March 2022. As a quick primer, this means there will now be five redress bands with a maximum fee charged per band.
More about us
September 27, 2022

How to get FCA authorised (part 1)

We are launching a new How To series on 'How to get FCA authorised'. This will look to cover a range of key items your business should consider from the location of offices, expected fees to resourcing. We will start on the first few key areas covering
More about us
August 9, 2023

Revised U.K. Financial Regulators' Complaints Scheme - Coming into effect 1, November 2023

In a collaborative effort, the Financial Conduct Authority (FCA), Prudential Regulation Authority (PRA), and Bank of England have unveiled their revised Complaints Scheme, which fundamentally shapes the protocol for addressing and managing grievances lodged against the U.K. regulatory bodies. This revamped framework encompasses several significant modifications:
More about us
May 23, 2025

Buy-Now-Pay-Later gets real: what the 2025 draft Order means for short-term interest-free credit – and why firms must start planning now

Five years on from the Treasury’s initial pledge, Parliament now has the Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 on its table
More about us
January 20, 2023

FCA's Portfolio Strategy on Claims Management Companies: A Detailed Compliance Guide for CMC Firms

The Financial Conduct Authority (FCA) recently released its Portfolio Strategy on Claims Management Companies (CMCs) outlining its approach to regulating this sector and identifying key risks.
More about us
April 11, 2021

FCA Cryptocurrency Regulation Part 1

From 10 January 2020, the FCA became the anti-money laundering and counter-terrorist financing (AML/CTF) supervisor for crypto firms, covering firms that exchange money to and from crypto assets and those that safeguard their customers crypto assets.
More about us
December 7, 2022

Are you aware of the FCA rules to protect consumers from rogue financial promotions

Did you know that the FCA has published a consultation paper and press release setting out how it proposes to operate a new authorisations gateway for firms wanting to continue approving financial promotions for unauthorised persons.
More about us

Your key contacts

ADEMOLA OMOSANYA

Ademola is an accomplished consultant with over a decade of experience across regulation, banking, and consumer credit. As MEMA Consultants co-founder, he leverages extensive regulatory expertise to guide clients through critical processes and full compliance. His experience across sectors enables tailored solutions to complex business challenges. Ademola partners with clients as a strategic advisor to help futureproof their business through an in-depth understanding of the regulatory landscape.

MISAH MARAGH

Misah is a director at MEMA Consultants with over a decade of experience in financial services. Holding a legal background and postgraduate qualification, she previously worked at the Financial Conduct Authority. Misah has led compliance transformation for global consumer services organisations across Europe, the Caribbean, and Latin America. Her expertise includes implementing compliance frameworks for financial regulations, FCPA, UK Bribery Act, data privacy, and Sarbanes-Oxley. Misah is skilled at advising clients on operational and strategic projects, leveraging her in-depth knowledge of regulatory environments to deliver solutions tailored to complex business needs.

Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.

Senior Managers And
Certification Regime