Category: Compliance & AML · Reviewed by Simon Temme, Account Executive · Last reviewed June 2026
A document required of Enhanced SM&CR firms (and dual-regulated firms) recording, on the handover from one Senior Manager to another, all material information and issues that the incoming Senior Manager could reasonably expect to need.
A handover certificate (or “handover material”) is information that an outgoing Senior Manager — or their firm — must prepare for an incoming Senior Manager to ensure the new postholder can perform their responsibilities effectively from day one. It is a critical accountability tool because incoming SMFs are responsible for matters within their SoR from the moment of appointment.
SYSC 25.9 of the FCA Handbook. Equivalent rule sits in the PRA Rulebook for dual-regulated firms.
The handover should be in writing, kept on file, and cover the key issues in the SMF holder’s area of responsibility: current performance against responsibilities, known significant risks and open matters, regulatory engagement history, pending issues, escalations and any matters under investigation. It is meant to be useful — not merely a legal formality — and supports the incoming SMF in taking reasonable steps from day one.
Only Enhanced firms are formally required to maintain handover material. Core firms (including most insurance brokers) are not formally required to, but good practice on any SMF change is to record a written handover and keep it on file. This also supports the firm’s general SYSC 9 record-keeping duty.
When a Director-level role transitions at a large broker, the outgoing SMF prepares a handover note covering the current PII renewal cycle status, the Consumer Duty implementation status, open regulator engagements, the regulatory return calendar and any in-flight remediation projects. The note is reviewed at the first board meeting after the change.
FCA Handbook, SYSC 25.9. PRA Rulebook, Allocation of Responsibilities. 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.
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