SM&CR solutions

SM&CR (SMCR) Compliance Solutions

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How the SM&CR (SMCR) impacts you

The Senior Managers and Certification Regime (SM&CR, or SMCR) came into effect on 9 December 2019 impacting approximately 47,000 solo-regulated financial firms.   

SM&CR is designed to improve accountability and enhance the focus on culture within financial services firms. The Financial Conduct Authority (FCA) implemented this regime for banks in early 2016 - and is now serious about enforcement.


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Are you confident your SM&CR programme meets compliance? 

The new regime may require substantial changes to your firm’s governance and culture. Firms now need to take stock of the policies, processes, and documentation that they have put in place.

Has the correct engagement taken place with individual employees to make the necessary changes that are required by the regulator?

Have your employees received bespoke SM&CR training on how it impacts their day-to-day roles? 

ACA provides a comprehensive and practical suite of SM&CR solutions, designed to help firms and individuals review and maintain compliance against the directive. Our SM&CR services include post-implementation assurance reviews of your firm's current framework and on-going assistance with employee assessments and training. 

Call us at +44 (0)20 7042 0560 to learn more

How We Help

As part of ACA’s post-implementation assurance review services, we help you fully consider the direct and indirect impact of SM&CR on your firm, with a specific focus on organisational and cultural changes required to fully implement the new regime.

Our SM&CR post-implementation assurance service includes:


Review of SM&CR documentation and internal processes


Interviews with key personnel to verify understanding of the new regime


Key findings and recommendations for improvement

Training on Conduct Rules for all staff

Including scheduled or tailored in-house sessions. 

Key Challenges 

In the course of helping numerous firms implement their SM&CR programmes, we have observed six concerns:

number 1

Embracing a governance structure and culture

number 2

Determining prescribed responsibility and whether it should be collective or individual

Documenting and maintaining details of individual roles, including statements of responsibility, job descriptions and employment contracts

number 4

Conducting fitness and propriety assessments, regulatory references and criminal records checks

number 5

Aligning and maintaining record keeping requirements of compliance, HR and legal

number 6

Comprehending code of conduct breaches and disciplinary processes