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ARTICLE · 02 JULY 2020

SMCR – Top Priorities For 2020/21

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The UK senior managers and certification regime ("SMCR") overhauled the accountability regime for individuals working in UK financial services firms and has been in force for just over two months...

United KingdomFinance and Banking
Kirsten Lapham
Kirsten Lapham
John Verwey
John Verwey
Amar Unadkat
Amar Unadkat
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Originally published on February 24, 2020. Updated as of July 1, 2020.

The UK senior managers and certification regime ("SMCR") overhauled the accountability regime for individuals working in UK financial services firms and has been in force for just over two months now. The regime applied to all FCA solo-regulated firms on 9 December 2019, but for most firms, there is still work to be done. In this Client Alert, we summarize the main issues firms will need to focus on to ensure full compliance with SMCR in 2020/21 and beyond. For further background and detail on SMCR, see our previous memo here.

1. The Certification Regime

The certification regime ("CR") applies to employees whose role means it is possible for them to cause significant harm to the firm, its customers or the market more generally (also referred to as 'Certification Functions'). Firms must check and certify that individuals holding certification functions are fit and proper to perform their role

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