Senior Managers and Certification Regime (SM&CR) and the Conduct Rules

Banks, building societies, credit unions and designated investment firms have been subject to SM&CR since 2016. In December 2018 the Regime extended to dual-regulated insurers and their managing agents.

In December 2019, a further extension now means that almost all FCA regulated financial services firms have requirements under the regime, including consumer credit and claims management companies (CMCs).

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Senior Managers and Certification Regime SMCR eLearning

The three pillars of the regulatory regime

Senior Managers Regime

Certification Regime

Conduct Rules

Senior Managers Regime

  • Firms must create and maintain Responsibilities Maps, identifying key Senior Manager Functions (SMFs) and the Prescribed Responsibilities (PRs) that those individuals hold.
  • SMFs must complete individual Statements of Responsibility (SoR) and have a Duty of Responsibility under the regime.
  • Individuals carrying out SMFs must be approved by the FCA and firms must undertake a criminal record check (in addition to fitness and propriety) when recruiting into an SMF role.

Certification Regime

  • Firms must certify the fitness and propriety of key employees who perform activities which may have a significant impact on customers and/or the firm.
  • Certificates must be issued to those individuals at least annually confirming that the firm has assessed their ongoing fitness and propriety to carry out the role.
  • Firms must submit changes to any of their certified population’s activities to the FCA’s public register (‘the Directory’) of Certified Persons.

Conduct Rules

  • Tier 1 Individual Conduct Rules apply to all employees, excluding ancillary staff not involved in regulated activities (e.g. cleaners, catering staff, etc.).
  • Tier 2 Senior Manager Conduct Rules apply to those in SMF positions and require them to take reasonable steps to control their areas of responsibility. Senior Management Conduct Rule 4 also applies to non-executive directors.

Our SMCR toolkit can support you


SM&CR and Conduct Rules Training Courses

Most staff in your firm will also need to undertake training in the Conduct Rules too. 

Fitness And Propriety

Fitness and Propriety Form Tracking

With Access LMS, you can automatically assign fit and proper assessments to be completed by individuals online, which can then be sent to managers to sign off through a workflow. 

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Functions and Responsibilities

Access LMS has a powerful SMR and CR tool to assist you with the task. Easy allocation of the functions and responsibilities can be achieved in just a few clicks with a full audit tracking facility. 

Statements Of Responsibilities

Statement of Responsibilities

Our SMR and CR tool can auto-generate a declaration that can be sent to those that need to review and accept. 

Responsibilities Map

Responsibilities Map

If your firm is dual-regulated or subject to the Enhanced Regime, you must produce and submit a RM. We have a tool that will seamlessly assist you with this task with easy editing, shared and interim responsibilities allocation plus full audit and tracking functionality. 

Our LMS Solutions

Our learning management system (LMS) solutions can help you meet all the demands of the regime with easy to navigate platforms, delivering eLearning and tools that cover requirements for all staff under the regime.

Reduce risk and safeguard your business with market-leading eLearning courses designed to meet the needs of any business operating in the Financial Services sector - find out more

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LMS features include

  • Inbuilt CPD tracking - Use the standard scheme or configure your own. Automatically log CPD time accrued as part of your relevant online learning activities, or manually add offline time.
  • Training and Competence - An integrated T&C feature helps firms comply with the FCA’s or a firm-specific regime, using a series of online forms underpinned by preset workflows to manage and evidence both competency and performance.
  • Reporting Tools - Enjoy out of the box reports, as well as the option to create custom reports depending on your requirements. Highlight risk across the organisation with clear graphical charts that are easy to access, collate and export.
  • Diagnostic Tools - Assess risk across your organisation, report by department, manager or area, and then deliver only targeted, relevant content.
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SM&CR and Conduct Rules Training

Our eLearning courses are a cost effective solution to ensure all relevant staff have the training needed to comply with the Senior Managers and Certification Regime (SM&CR) and Conduct Rules (which now applies to most staff in FCA-regulated firms).

Working in collaboration with industry-leading experts Financial Services Training Partners (FSTP), our Conduct Rules eLearning enables users to select from one of over 50 examples to see a case study tailored to their role, demonstrating how the Conduct Rules will apply to them (part of the FCA's requirement).


Discover more about the SM&CR toolkit

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SM&CR consultancy with our partners, FSTP

Our joint solution provides flexible support, from help with understanding what information needs uploading to the SM&CR tool, to facilitating a board meeting or deciding who is taking which prescribed and other responsibilities. It enables you to make the best use of the technology to evidence SM&CR requirements and free up resource to deliver business as usual.

You can take a holistic approach to the support services on offer or just pick the ones that you need for your business.

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