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SMCR: Extended deadline for solo-regulated firms

The Senior Managers and Certification Regime (SMCR) applied to solo-regulated firms from 9 December 2019 and required certain steps to be taken by 9 December 2020 [1].

As part of its response to reduce the burden on firms affected by the Covid-19 pandemic, the Financial Conduct Authority (FCA) extended the deadline for the following requirements from 9 December 2020 to 31 March 2021 [2]:

  • the date the Conduct Rules come into force, for staff who are not Senior Managers, Certification Staff or board directors
  • the date by which relevant employees must have received training on the Conduct Rules
  • the deadline for submission of information about Directory Persons to the Register
  • references in its rules to the statutory deadline for assessing Certified Persons as fit and proper following agreement with the Treasury

The FCA says that firms should continue with their programmes of work in these areas and, if they are able to certify staff earlier than March 2021, they should do so. They should not wait to remove staff who are not fit and proper from certified roles.

In giving extra time to firms that need it, the FCA is reiterating the importance of the Certification Regime and Conduct Rules. Culture remains a key area of focus for the FCA, emphasised in a recent speech on ‘The business of social purpose’.

Firms are reminded that the Senior Managers Regime is already in force and Senior Managers remain fully accountable for their areas of responsibility during and after the pandemic. The Conduct Rules also continue to apply for Senior Managers and Certified staff.

The FCA’s comprehensive SMCR webpage for solo-regulated firms can be found here.

Practical details about submission of Directory Persons data can be found here.

Should you have any queries or require any assistance, please do not hesitate to contact Jeanette Burgess or any member of the Regulatory & Compliance team.


[1] See our briefings Extension of the Senior Managers and Certification Regime: Part 1 and Extension of the Senior Managers and Certification Regime: Part 2

[2] See Policy Statement PS20/12

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