Responsibilities map

Category: Compliance & AML · Reviewed by Mark Fox, Broker · Renewals · Last reviewed June 2026

A single document required of Enhanced SM&CR firms (and dual-regulated firms) showing the firm’s overall governance and how every Senior Management Function, Prescribed Responsibility and Other Overall Responsibility is allocated and connected.

Definition

A Responsibilities Map is a firm-level document required of Enhanced solo-regulated firms and PRA-designated firms. It sets out the firm’s overall governance, the SMFs in place, the Prescribed Responsibilities (PRs) allocated, the Other Overall Responsibilities (OORs) for material business activities, the reporting lines, and the committee structures. It complements — does not duplicate — the individual Statements of Responsibilities.

Legal / Regulatory basis

SYSC 25 of the FCA Handbook. Equivalent provisions sit in the PRA Rulebook (Allocation of Responsibilities) for dual-regulated firms.

How it works in practice

The Map provides one view of the entire senior accountability framework. It must show: the SMFs, the PRs and how they are allocated to specific SMFs, the OORs and how they are allocated, the matters reserved to the board, committee terms of reference, and the reporting relationships. The Map is updated when responsibilities change and submitted to the FCA when material changes are made.

Common variations

Only Enhanced solo-regulated firms need a Responsibilities Map. Most insurance intermediaries (including Apex) are Core firms and do not need one — though they still need individual SoRs for each SMF holder.

Example

A large national insurance broker that is an Enhanced firm would maintain a Responsibilities Map showing how Compliance Oversight (allocated to SMF16), Internal Audit (allocated to SMF5 if held), Money Laundering Reporting (SMF17), Conduct Rules training, financial crime systems and Consumer Duty implementation each sit within the firm’s governance.

See also

• Statement of responsibilities
• Senior Management Functions (SMF)
• Handover certificate
• Senior Managers and Certification Regime (SM&CR)

References

FCA Handbook, SYSC 25. PRA Rulebook, Allocation of Responsibilities (dual-regulated firms). 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.