Approved Persons regime (legacy)

Category: Compliance & AML · Reviewed by Chrissie Anderson, Client Executive · Last reviewed June 2026

The pre-SM&CR FCA regime, in force from N2 (December 2001) until 9 December 2019 for solo-regulated firms, under which named individuals were approved to perform listed Controlled Functions.

Definition

The Approved Persons Regime (APR) was the UK accountability framework for individuals performing controlled functions in authorised firms before SM&CR. Under APR, the FCA approved individuals to perform a list of specific controlled functions, each carrying a numerical identifier — CF1 (Director), CF10 (Compliance Oversight), CF11 (MLRO) and so on. The Approved Persons Statements of Principle (APER) imposed personal standards equivalent to the present Conduct Rules.

Legal / Regulatory basis

Originally FSMA section 59 (controlled functions) and APER. Repealed and replaced — for banks and insurers from 7 March 2016, and for FCA solo-regulated firms from 9 December 2019 — by the SM&CR provisions in FSMA sections 59ZA, 60, 60A, 63E and 64A.

How it works in practice

Under APR, an individual could not perform a controlled function unless approved by the FCA. The approval was granted on a fit-and-proper basis. APER set seven Statements of Principle and four Code of Practice for Approved Persons. The CF map distinguished significant influence functions (e.g. CF1 Director, CF3 Chief Executive) from customer functions (CF30, dealing with customers).

Common variations

The migration to SM&CR was achieved through Form K or Form O conversion processes. Most CF holders converted to corresponding SMFs (CF1 → SMF3, CF10 → SMF16, CF11 → SMF17). Customer functions (CF30) typically converted to the Certification Regime — there is no longer a need for FCA pre-approval for customer-facing roles, but the firm certifies them annually.

Example

A historical Final Notice that pre-dates 2019 will reference APER principles rather than COCON Conduct Rules. The substance is similar — integrity, skill, care and diligence, market conduct, and proper standards — but the formal hooks differ.

See also

• Senior Managers and Certification Regime (SM&CR)
• Senior Management Functions (SMF)
• Certification Functions
• Conduct Rules — tier 1 (Individual)

References

FCA Handbook (historic), APER and SUP 10A (legacy). Financial Services and Markets Act 2000 (historic), section 59. FCA Policy Statement PS18/14.

Last reviewed

By Matt Bartlett, Director, on 2026-06-11.

This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.