The publication of the FCA’s Policy Statement PS26/6 marks the culmination of the first phase of reform to the Senior Managers and Certification Regime (SM&CR). While the direction of travel was clearly set out in CP25/21 (July 2025), the final rules reveal a more calibrated outcome, one shaped by industry feedback, operational realities, and the limits of the regulators’ current rule-making powers.
The FCA has indicated that, subject to proposed changes by HM Treasury, a second phase of more comprehensive SM&CR reforms is expected to be consulted on later in 2026. These may address deeper structural aspects of the regime.
Implementation follows a staged timetable. Core changes came into force on 24 April 2026 and will be followed by reporting and process updates on 10 July 2026, and conduct-related changes aligned with non-financial misconduct reforms on 1 September 2026. This phased approach gives firms time to adapt systems, controls and governance frameworks.
- The 12-Week Rule – Proposal Largely Implemented
CP25/21 proposed amending the 12-week rule so that firms would have 12 weeks to submit an SMF application, rather than requiring approval within that timeframe.
What PS26/6 delivers:
Firms now have 12 weeks to submit an application, and individuals may perform the role during this period under the revised framework. The FCA has also provided additional clarity on how the rule should be used in practice.
- Criminal Record Checks – A Clear Burden Reduction
CP25/21 proposed reducing duplication and friction in criminal record checks, particularly for internal moves.
What PS26/6 Delivers:
- Extend validity periods (e.g. from three to six months)
- Remove requirements in certain intra-group or internal transitions
- Certification Regime – Signposted Reform, Limited Delivery
The consultation signalled more than operational change, including removal of duplication and the potential future replacement of the Certification Regime in Phase 2.
What PS26/6 delivers:
Phase 1 introduces streamlined certification processes and greater flexibility, including the use of digital certification and alignment with appraisal cycles. However, there is no structural reform of the regime and no reduction in scope at this stage.
- Statements of ResponsibilitiesandManagement Responsibilities Maps – Meaningful Simplification
CP25/21 identified documentation as a key area of burden, proposing simplification of:
- Statements of Responsibilities (SoRs)
- Management Responsibilities Maps (MRMs)
What PS26/6 Delivers:
- Less frequent updates (e.g. periodic/bulk submissions)
- Reduced administrative expectations
- Regulatory References – A Partial Recalibration
CP25/21 proposed to improve proportionality and reduce administrative overheads.
What PS26/6 Delivers:
While some clarifications have been introduced, the final rules also:
- Shorten the deadline for providing references (from six to four weeks)
- Conduct Rules – Clarification with Subtle Tightening
CP25/21 proposed clarification of expectations and improved consistency in application.
What PS26/6 Delivers:
In addition to clarification, the FCA has:
- Reinforced expectations around internal escalation and notification obligations
- Indicated that failures in this area may breach Senior Manager Conduct Rules
- SMF Scope (SMF7 & SMF18) – Clarification, Not Expansion
CP25/21 indicated a clarification of the scope and application of certain SMFs, particularly in group contexts.
What PS26/6 Delivers:
The FCA has largely
- Maintained existing scope
- Provided additional guidance rather than expanding requirements
- Directory, Reporting and Processes – Deferred Implementation
CP25/21 suggested streamlining reporting obligations and improving operational processes.
What PS26/6 Delivers:
Changes are implemented, but with delayed commencement (July 2026) to allow system updates.
- What the FCA Did Not (and Could Not) Implement
CP25/21 signalled more fundamental reform, including potential replacement of the Certification Regime, a reduction in SMF approvals, and broader structural simplification.
PS26/6 confirms:
These changes require legislative reform and will be considered as part of Phase 2. HM Treasury has indicated openness to removing the Certification Regime from statute and enabling a more flexible framework in the future.
How Complyport can help?
- SM&CR Impact Assessment and Implementation Support: We help firms translate the Phase 1 reforms into practical action. This includes assessing the impact of changes such as the revised 12-week rule, updates to regulatory references, and conduct rule expectations. We identify gaps in current SM&CR frameworks and support the design of proportionate, regulator-ready implementation plans ahead of the April, July, and September 2026 milestones.
- Senior Manager Governance and Documentation Optimisation: With simplification of SoRs and MRMs, firms have an opportunity to reduce administrative burden while maintaining clarity. We support: Redrafting and rationalising SoRs, Streamlining MRMs to reflect actual governance structures and embedding more efficient update and submission processes All while ensuring continued compliance with FCA expectations on accountability.
- Conduct Rules and Accountability Framework Strengthening: Given the FCA’s reinforced expectations around escalation and notification, we help firms reassess their conduct frameworks by: Enhancing internal escalation procedures and Reviewing breach reporting and investigation processes
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