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ARTICLE · 17 SEPTEMBER 2025

UK SMCR Reform: Consultations, Proposals And Next Steps

Proskauer Rose LLP
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The UK government and regulators are conducting the most wide‑ranging review of the Senior Managers & Certification Regime (SMCR) since its introduction.

United KingdomFinance and Banking
Andrew Wingfield
Andrew Wingfield
John Verwey
John Verwey
Anna Maleva-Otto
Anna Maleva-Otto
Anna Sykes
Anna Sykes
Sulaiman Malik
Sulaiman Malik
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Executive Summary

The UK government and regulators are conducting the most wide‑ranging review of the Senior Managers & Certification Regime (SMCR) since its introduction.

  • Phase One – Financial Conduct Authority (FCA) & Prudential Regulation Authority (PRA) consultations (CP25/21 and CP18/25): Targeted reforms to streamline approvals, certification, governance documentation and temporary cover, alongside internal regulator improvements.
  • Phase Two – HM Treasury consultation: Proposes removing the Certification Regime from legislation and transferring it fully into FCA/PRA rulebooks – the most significant potential reform since 2016.
  • Phase Three – Further changes: Likely once legislative amendments are in place, potentially reducing senior manager roles, altering pre‑approval requirements and reshaping responsibilities.

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