NPA launch guidelines for SMCR


Phase 1

On 9th December 2019, the FCA will be making major changes to the governance of all FCA regulated firms. The ‘Senior Managers and Certification Regime’ replaces ‘Approved Persons’ and adds some additional requirements. NPA have provided guidance for members and will be producing a series of 3 phased documents to help members through the process leading up to December.  

The Phase 1 document focuses on actions members should aim to complete by the end of July 2019 at the latest.

The phases include;

Complete by

end July 2019

Phase 1

Checking your Approved Persons, Functions and Reporting Lines are up to date on FCA Connect.


August/September 2019

 Phase 2

Creating Statements of responsibility for Senior Managers (SMs).

September - 9th December

 Phase 3

Creating HR policies for Senior Managers recruitment and updating policies and procedures, and training programmes.


Members are asked to check the SMCR section of the members resource area in the NPA website for latest updates and templates.

FCA Head Of Conduct, David Blunt will be speaking at the NPA Conference on 11th October and will update members on the SMCR regime.