Category: Compliance & AML · Reviewed by Mark Fox, Broker · Renewals · Last reviewed June 2026
The UK accountability regime that imposes individual responsibilities on senior managers, requires firms to certify the fitness of staff in customer-impacting roles, and applies Conduct Rules to almost every employee of a regulated firm.
The Senior Managers and Certification Regime (SM&CR) is the UK framework for individual accountability in regulated financial services firms. It replaced the older Approved Persons Regime (APR) for banks and insurers from 2016 and for FCA solo-regulated firms (including insurance intermediaries) from 9 December 2019.
The statutory basis is FSMA, particularly section 59ZA (senior management functions), section 60 (FCA approval of senior managers), section 60A (assessment of fitness and propriety), section 63E (certification), section 64A (rules of conduct) and Schedule 1ZB. The detail sits in SYSC 23–27 of the FCA Handbook, supported by the Code of Conduct sourcebook (COCON) for individuals and Form A, Form C and Form D in SUP 10C.
SM&CR has three pillars. (1) The Senior Managers Regime: pre-approval by the FCA for individuals performing a Senior Management Function (SMF), each with a written Statement of Responsibilities (SoR). (2) The Certification Regime: firms must annually certify employees performing Certification Functions as fit and proper to do so. (3) The Conduct Rules: tier 1 rules apply to almost all staff and tier 2 rules apply to senior managers. Solo-regulated firms are split into Limited Scope, Core, and Enhanced tiers based on size and activities.
Most FCA-regulated insurance brokers, including Apex, fall in the Core tier. SMFs in a Core firm typically include SMF3 (Executive Director), SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting Officer). Limited Scope firms (e.g. sole traders, certain credit broking firms) face a reduced set. Enhanced firms (the largest solo-regulated firms) face the same regime as banks, including responsibilities maps, handover certificates and Overall Responsibility Functions.
At Apex, Matt Bartlett (Director) holds the SMF3 Executive Director and the SMF16 Compliance Oversight and SMF17 MLRO functions, with the SoR for each filed with the FCA. The firm’s senior team review fit-and-proper status annually and document the assessment. Conduct Rules training is delivered at induction and refreshed annually for all staff.
FCA Handbook, SYSC 23–27, COCON, SUP 10C. Financial Services and Markets Act 2000, sections 59ZA, 60, 60A, 63E, 64A, Schedule 1ZB. FCA Policy Statement PS18/14 (Extending SM&CR to FCA solo-regulated firms).
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.
Get a quote