SM&CR solutions

SM&CR (SMCR) Compliance Solutions

Contact Us

Are you ready for SM&CR (SMCR)?

The Senior Managers and Certification Regime (SM&CR, or SMCR) comes into effect on 9 December 2019 for solo-regulated firms, impacting approximately 47,000 financial firms. SM&CR was designed to improve accountability and enhance a financial services firm's focus on the culture within. The Financial Conduct Authority (FCA) has already implemented this regime for banks - and is serious about enforcement.  

ACA provides a comprehensive and practical suite of SM&CR planning solutions, designed to help firms and individuals achieve and maintain compliance when the regulation comes into effect. Our SM&CR services range from full implementation of the regime to a review of your firm's current project programme.

Contact us to learn more: Call Sam Reid or Carl Day at +44 (0)20 7042 0560

  • days
  • Hours
  • Minutes
  • Seconds
blue gradient

people at desk in conference room discussing talking

How does this impact you? 

Many firms need to accelerate the pace at which they are preparing for SM&CR. The amount of work required ahead of the deadline cannot be underestimated.  For some firms, the coming of this new regime will necessitate substantial changes to both governance and culture.

If you are solo-regulated firm, there are new policies, processes, and documentation that you must implement. The engagement that needs to take place with certain individual employees will take time to prepare to make the necessary changes to your overall business culture, as required by the regulator. In addition, you will need to make sure you train your employees across your firm on SM&CR individually, as it will in many cases touch on their day-to-day roles.

It’s important for firms to start working on SM&CR in earnest today.  We can provide you with the essential elements to help you become compliant with the new regime.  

Contact us to learn more: Call Sam Reid or Carl Day at +44 (0)20 7042 0560.

How We Help

ACA’s complete suite of solutions provides:

Access to ACA’s tailored Implementation Planner and Timetable

Including initial dialogue with your Compliance Officer, Legal Counsel and/or SM&CR project lead, to provide ACA consultants with a high-level overview of your firm’s needs.


Senior Management briefings

To reinforce the new governance arrangements for your firm and the significant liabilities SM&CR will impose on certain key individuals.


Implementation Planning and Support

Including services tailored to your firm’s specific business model, circumstances and agreed needs.


Review and update of your firm’s existing Compliance Framework documents and provision of key SM&CR materials

Including a Statement of Responsibility for Senior Management Functions, Fitness and Propriety assessments for Senior Managers and Certification staff, and a Conduct Breaches register.


Training on Conduct Rules for all staff

Including scheduled or tailored in-house sessions. 

Call Sam Reid or Carl Day on +44 (0)20 7042 0560 to learn how ACA can help your firm overcome its SM&CR implementation challenges. 

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 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 the record keeping requirements of compliance, HR and legal

number 6

Comprehending code of conduct breaches and disciplinary processes