Statement of responsibilities

Category: Compliance & AML · Reviewed by Taylor Watts, Broker · New Business · Last reviewed June 2026

The single self-contained document, filed with the FCA on each application or material change, that describes the responsibilities of a Senior Manager — both Prescribed Responsibilities and any other responsibilities allocated by the firm.

Definition

A Statement of Responsibilities (SoR) is a written document describing the matters for which a particular Senior Manager is responsible. Every SMF holder must have one; it is submitted on application for approval and resubmitted whenever the responsibilities change. The SoR is the document the FCA examines when assessing whether an individual has taken reasonable steps under the Duty of Responsibility.

Legal / Regulatory basis

FSMA section 60(2A) requires the SoR to accompany an application for approval. FSMA section 62A requires resubmission on any significant change. SUP 10C.11 in the FCA Handbook sets out the SoR rules.

How it works in practice

An SoR is a standalone document — typically 1–3 pages — covering the SMF holder’s overall management responsibilities, any Prescribed Responsibilities (PR) allocated under SYSC 26 (for Enhanced firms — Core firms do not have PRs), other significant responsibilities, governance and committee roles, and any reporting lines. It must be self-contained: it cannot be understood only by reference to other documents.

Common variations

For Enhanced firms there is also a Responsibilities Map showing how Prescribed Responsibilities and other responsibilities are allocated. Core firms (most insurance brokers, including Apex) do not require a Responsibilities Map, but do require SoRs for each SMF holder.

Example

At Apex, the SoR for the SMF3 Executive Director holder records strategic leadership of the firm, capital and PII oversight, regulatory engagement, and overall regulatory responsibility. The SoR for SMF16 records compliance oversight, complaint-handling oversight, Consumer Duty implementation oversight, and policy approval. The SoR for SMF17 records financial crime systems and controls, SAR submission and MLR 2017 compliance.

See also

• Senior Management Functions (SMF)
• Responsibilities map
• Handover certificate
• Duty of Responsibility
• Senior Managers and Certification Regime (SM&CR)

References

FCA Handbook, SUP 10C.11. Financial Services and Markets Act 2000, sections 60(2A), 62A. 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.