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FCA confirms SM&CR implementation delay

  • 28/10/2020
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The Financial Conduct Authority (FCA) has confirmed it is giving a 16-week extension for firms to meet the next wave of requirements in its Senior Managers and Certification Regime (SM&CR).


Firms will now have until 31 March to implement the requirements which apply to all staff and include submitting details to the FCA register.

In its response to the consultation, the FCA said almost all respondents were supportive of the delayed deadline and most firms were in place to meet the original 9 December deadline.

As a result it urged firms to continue working towards that goal where possible.

One respondent was concerned the extension would reduce the perceived importance of the SM&CR.

The regulator acknowledged there was a small risk that delaying implementation periods could reduce the perceived importance of the SM&CR.

But it said it had balanced this against the need to “support firms under exceptional stress from the coronavirus pandemic and to give them the time to fully and properly implement the Certification Regime and to train staff effectively in the Conduct Rules”.

It said: “Effective implementation of the Certification Regime and the training of staff in the conduct rules are essential for delivering an enduring positive impact on capabilities and culture – and therefore reducing harm in the long term.

“It is precisely because the SM&CR is so important that we want to give firms the time they need to make lasting improvements to their conduct and culture.

“Extending the deadlines as we proposed means that firms will not have to choose between meeting their regulatory deadlines and realising their plans to achieve a full and effective implementation of the Certification Regime and conduct rules.”


Actions delayed until 31 March 2021 are:

  • 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 our rules to the statutory deadline for assessing certified persons as fit and proper following agreement with the Treasury.


Implementation deadlines for Claims Management Companies (CMCs) have also been extended by an equivalent period.

This means a CMC receiving full authorisation on or after 9 December 2019 will have just over 15 months after the date of its full authorisation to meet the same set of requirements in paragraph.




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