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FCA consults on a second phase of SM&CR reforms

The regulator proposes changes to certification and senior management processes; responses are due by 22 January 2027.

Published Source date 22 October 20262 min readBy GRC.me.uk editorial desk · AI-assisted

Read with the right scope

UK financial services firms in or entering the SM&CR, including third-country branches. Dual-regulated firms should also consider the PRA consultation.

Status: Open consultation; proposed changes are not final rules.

What is proposed

The FCA opened the second phase of its SM&CR review on 22 October. Consultation CP26/37 proposes removing the Certification Regime and retiring the directory of certified and assessed persons, alongside changes to senior management approvals, responsibilities and conduct reporting.

Other proposals include raising thresholds for the Enhanced regime and removing ongoing submissions of responsibility statements and maps. The FCA says its aim is to simplify operation while preserving individual accountability and conduct standards.

Consultation timing

Responses are due by 22 January 2027. The regulator expects to publish final requirements in the first half of 2027, so these proposals should not be treated as rules already in force.

Firms supervised by both the FCA and PRA should also consider the PRA’s parallel consultation.

Practical implication — editorial

For affected GRC teams, the immediate task is to map potential changes against existing ownership, certification and reporting processes and decide whether to respond.

Part of the compliance guidance hub. See how the GRC framework connects the disciplines.

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Sources & verification

  1. FCA — CP26/37: Senior Managers and Certification Regime (SM&CR) Review: Phase 2 ↗Source published 22 October 2026 · Source checked 2 November 2026 · Primary source

The source list records when each reference was checked. AI-assisted research and drafting; no independent human legal review is claimed. Check for later changes and advice appropriate to your circumstances.