SMCR is coming – are you ready?

SMCR is coming – are you ready?

SMCR will soon go live – how should firms prepare?


Director, Financial Risk Management

KPMG in the UK


Also on

sand time jar

The Senior Managers and Certification Regime (“SMCR”) for FCA solo-regulated firms is due to go live in December 2019 and replaces the current Approved Persons Regime (“APER”). It raises the level that Senior Managers need to demonstrate that they are adequately able to oversee their areas of the business and obliges firms (not the regulator) to regularly assess and certify their client-facing and other critical staff as “Fit and Proper”.

The regime aims to reduce harm to consumers and strengthen market integrity by creating a system that enables firms and the FCA to hold people to account.

Implementing this regime can pose challenges and key questions which firms will need to adequately consider to ensure readiness and compliance with the regime by go-live. This will include potential changes to governance arrangements as well as updating and creating firm documentation and policies to accurately reflect the new requirements on the firm.

We have spent the last five years helping banks, building societies, major investment firms and insurers on the design and implementation of individual accountabilities programmes so that they can meet the requirements of SMCR and the Senior Managers Regime for Insurers. Our flyer is designed to help firms entering into the regime in 2019 for the first time think about different aspects of the regime and challenge themselves on how prepared they are for its introduction.

© 2021 KPMG LLP a UK limited liability partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organisation please visit

Connect with us


Want to do business with KPMG?


loading image Request for proposal

Save, Curate and Share

Save what resonates, curate a library of information, and share content with your network of contacts.

Sign up today