Category: Compliance & AML · Reviewed by Al Jabbar, Broker · Specialist Risks · Last reviewed June 2026
The standardised reference that one regulated firm must provide about a former employee to a prospective firm where that employee will perform a senior management, certification or other prescribed function — covering up to six years of disciplinary, conduct and propriety information.
A regulatory reference is a mandatory information exchange between regulated firms when an individual moves to a Senior Management Function, Certification Function, Non-Executive Director role on the board, or certain other prescribed roles. The reference covers conduct-related information about the previous employment so that the recruiting firm can make a properly informed fitness assessment.
SYSC 22 of the FCA Handbook implements the regime. It is supported by FSMA section 60A (the fitness assessment obligation) and PRA Rulebook equivalents for dual-regulated firms.
A regulatory reference must be requested by the recruiting firm before approval (for SMFs) or before certification (for certified staff). The previous firm must respond promptly with the prescribed information using the SYSC 22 Annex 1 template. Look-back is six years for most matters and indefinite for any finding that the individual was not fit and proper. Information covered includes Conduct Rule breaches (whether or not formally found), disciplinary action, findings of misconduct, dismissal for misconduct and ongoing investigations.
For ancillary insurance intermediaries and Limited Scope firms, the scope is reduced. Outside the regulated population (or for purely commercial reference requests) there is no mandatory regulatory reference, but firms must still maintain enough record-keeping to be able to provide one if asked. Firms must update a previously provided reference if they become aware of new relevant information within the look-back period.
When recruiting a new client executive, Apex sends a SYSC 22 reference request to the previous regulated employer. The firm must respond within a reasonable time using the Annex 1 template. The reference forms part of the fitness assessment evidence base retained on file.
FCA Handbook, SYSC 22 and SYSC 22 Annex 1. Financial Services and Markets Act 2000, section 60A. FCA Policy Statement PS16/22 (Strengthening accountability — final rules including regulatory references).
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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