Category: Compliance & AML · Reviewed by Simon Temme, Account Executive · Last reviewed June 2026
The set of regulated roles in an authorised firm that require pre-approval by the FCA (and, for dual-regulated firms, the PRA), each carrying a defined scope of responsibility documented in a Statement of Responsibilities.
A Senior Management Function (SMF) is a specific role within an authorised firm that the FCA designates as one for which individual pre-approval is required. An individual cannot perform the role until the FCA approves them; the approval is given by reference to a specific SMF identifier and is recorded on the Financial Services Register.
FSMA section 59ZA defines a senior management function, FSMA section 60 sets the FCA’s approval mechanism, and FSMA section 60A sets the fitness-and-propriety test. The full SMF list for FCA solo-regulated firms is in SUP 10C.4.
For Core firms — the population that includes most general insurance intermediaries — the standard SMFs are SMF3 (Executive Director), SMF9 (Chair), SMF16 (Compliance Oversight), SMF17 (MLRO), SMF27 (Partner) and SMF29 (Limited Scope Function for limited-scope firms). Enhanced firms add SMF1 (Chief Executive), SMF24 (Chief Operations), SMF18 (Other Overall Responsibility) and others. Each SMF holder has a Statement of Responsibilities and is subject to tier 1 and tier 2 Conduct Rules and the Duty of Responsibility.
A single individual may hold multiple SMFs simultaneously (typical in small firms — for example one director holding SMF3, SMF16 and SMF17). Limited scope firms have SMF29 in lieu of SMF3/16/17. New SMF holders join via Form A; departures via Form C; material changes via Form D.
At Apex (a Core SMCR firm), Matt Bartlett is FCA-approved for SMF3 (Executive Director), SMF16 (Compliance Oversight) and SMF17 (MLRO). The Statement of Responsibilities for each is reviewed at least annually and on any material change of role, with version control retained for at least ten years.
FCA Handbook, SUP 10C.4. Financial Services and Markets Act 2000, sections 59ZA, 60, 60A. 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.
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