Category: Compliance & AML · Reviewed by Matt Bartlett, Director · Founder · Last reviewed June 2026
Roles within an authorised firm that are not pre-approved by the FCA but that the firm itself must certify, at least annually, as performed by an individual who is fit and proper.
A Certification Function is a role within a regulated firm that materially affects customer or market outcomes but is not pre-approved by the FCA. Instead, the firm itself must assess the individual’s fitness and propriety at recruitment and at least annually thereafter, issuing a certificate confirming the assessment.
FSMA section 63E (issuing of certificates), section 63F (issuing of certificates: supplementary), and FSMA section 63(2A) (the duty to issue a certificate annually). The detailed scope sits in SYSC 27 of the FCA Handbook.
For Core SMCR firms, Certification Functions include the Significant Management Function (where applicable), the Material Risk Taker function (rare for general intermediaries), the Client-Dealing Function (those who deal with customers in regulated business), the Algorithmic Trader function (not applicable to general intermediaries), CASS Oversight, Anti-Money Laundering Function (where not held by SMF17) and others. Each certified employee must be assessed against fitness criteria — honesty, integrity and reputation, competence and capability, and financial soundness — at least annually.
Certification does not require FCA approval. It is the firm’s responsibility to assess and certify. Records of the assessment must be retained. Where an individual fails the assessment, the firm must not issue a certificate; the individual cannot perform the role and the firm must take steps to remove them or restructure their duties.
At Apex, Client Executive Chrissie Anderson, in her client-dealing capacity, is within the Certification Regime. The annual certification process includes review of regulatory references received and (on departure) provided, complaint records, training completion, conflicts disclosures and any material concerns raised by line management.
FCA Handbook, SYSC 27. Financial Services and Markets Act 2000, sections 63E, 63F, 63(2A). FCA Policy Statement PS18/14.
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.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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