Published on 5 June 2026
Jurisdiction: United Kingdom
Tags: FCA SMCR reforms 2026, PS26/6, FCA policy statement, Senior Managers and Certification Regime changes, FCA governance requirements 2026, SMCR compliance updates, FCA 12‑week rule changes, FCA conduct rules 2026, SMCR certification regime guidance
On 22nd April 2026, the FCA published Policy Statement 26/6: Senior Managers & Certification Regime Review (PS26/6) setting out changes to the Senior Managers and Certification Regime (SM&CR) as part of the first phase of reforms. Most of the Phase 1 changes took effect on 24th April 2026, with the remainder taking effect on 10 July 2026.
The Phase 1 reforms that take effect on 24th April 2026 are summarised below.
Criminal records checks: The validity period for criminal record checks for a Senior Manager Function (SMF) holder has been extended from 3 to 6 months. Additionally, the requirement for firms to undertake criminal record checks where an existing SMF holder is applying for an SMF role in the same firm or group has been removed.
Senior Managers Regime – the 12-week rule: Firms are now allowed 12 weeks to submit a SMF application rather than 12 weeks to submit the application and receive approval. This can either be for a permanent candidate or for an interim one where recruiting a permanent candidate would take longer than 12 weeks.
Further guidance on SMF7 and SMF18 roles: The FCA has introduced further guidance to help firms determine whether a person is captured by the SMF7 (group entity senior manager) and SMF18 (other overall responsibility function) functions.
Statements of Responsibilities (SoRs) and Management Responsibilities Maps (MRMs): Firms can now submit updated SoRs (and MRMs where relevant) at least once every 6 months rather than submitting changes as they occurred. Firms can continue to report changes more frequently if they prefer.
Certification Regime (CR): The FCA has issued guidance setting out expectations when firms are recertifying individuals as Fit and Proper. The new guidelines clarify that email certificates are sufficient and firms may incorporate certification into annual appraisal cycles.
Directory of certified and assessed persons: Firms are now allowed 20 business days to update most of the information on the FCA Directory, however the 7 working day timescale for updating details about staff departures remains unchanged.
Regulatory references: In order to address concerns about recruitment delays caused by the time taken to receive regulatory references, the updated guidance says firms should aim to provide regulatory references within 4, rather than 6, weeks of a request. Additional guidance has been introduced on what may need to be included in a regulatory reference if an employee leaves the firm before an investigation into potential misconduct has concluded.
Conduct Rules: New guidance has been introduced to:
Reiterate that only Conduct Rule breaches where specified disciplinary action was taken by the firm need to be notified to the regulator.
Highlight that the notification requirements for breaches under SUP 15.11 are separate from any other reporting requirements.
Outline matters that the regulator might expect notification about under Senior Manager Conduct Rule 4 (SC4), and proposed guidance on Senior Manager Conduct Rule 2 (SC2).
Clarify the impact of legal privilege on SC4.
Clarify when cases in which the firm suspended an individual, or reduced or recovered their remuneration, need to be notified to the regulator.
Clarify regulatory reference expectations where an individual has breached a Conduct Rule and specified disciplinary action was not taken.
The following SM&CR Phase 1 changes take effect on 10th July 2026:
Prescribed Responsibilities: A rule change to allow SMF18s at solo-regulated firms to hold any prescribed responsibilities.
Thresholds for becoming an Enhanced SM&CR firm: The FCA has raised certain financial thresholds for becoming an Enhanced SM&CR firm by updating them in line with inflation, and has created a mechanism for updating these thresholds every 5 years, so they keep up with inflation.
Certification Regime: The FCA will remove duplication in the Certification Regime by removing the need to certify the same individuals to perform multiple overlapping functions.
How can we help?
We can assist with:
Producing and co-ordinating an implementation plan specific to your firm
Preparing a board briefing note summarising PS26/6
Formulating a gap analysis template for SM&CR Phase 1
Drafting of updated SoR and MRM templates aligned to the new rules
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