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Approved Persons, Senior Manager and Certification Regimes: financial services

Updating authors: Paul Ellison
Consultant editor: Nick Thorpe and David Palmer

NOTE: The Senior Managers Regime (SMR) and Certification Regime (CR) apply to all UK-incorporated banks, building societies, credit unions and PRA-regulated investment banks (s.71A Financial Services and Markets Act 2000) and replace the Approved Persons Regime for individuals working within those firms. The SMR and CR were extended to insurers on 10 December 2018, and will be extended to all FCA-authorised firms, which includes asset managers, brokers and consumer credit firms, from 9 December 2019.


  • In firms where the Approved Persons Regime still applies, individuals performing controlled functions must be approved in advance by the Financial Conduct Authority (FCA) as approved persons (s.59 of the Financial Services and Markets Act 2000). (See Approved Persons Regime)
  • A list of controlled functions is included in the FCA Supervision sourcebook. (See What are controlled functions?)
  • Approved persons must be assessed as fit and proper. (See Requirement to be a fit and proper person)
  • The standards of behaviour that the FCA expects of approved persons are set out in the Statements of Principle and Code of Practice for Approved Persons. (See Statements of Principle and Code of Practice for Approved Persons)
  • Failure to comply with the Code of Practice for Approved Persons may result in enforcement action by the FCA. (See Enforcement)
  • The Senior Managers Regime (SMR), which currently applies to all UK-incorporated banks, building societies, credit unions, investment banks and insurers, requires senior managers of relevant firms who carry out senior management functions to be pre-approved by the PRA or FCA. (See Senior Managers Regime)
  • The SMR and Certification Regime (CR) were extended to insurers and reinsurers on 10 December 2018. The extended regimes replace the Senior Insurance Managers Regime and the revised Approved Persons Regime for insurers. (See Insurers - Senior Insurance Managers Regime)
  • Prescribed responsibilities set by the PRA and FCA must be allocated between senior managers. (See Prescribed responsibilities)
  • Each senior manager must have a statement of responsibilities that sets out what he or she is responsible for and what prescribed responsibilities he or she undertakes. (See Statement of responsibilities)
  • Firms must also keep up-to-date management responsibilities maps that record which senior manager is responsible for which prescribed responsibility and ensure that there is no gap in the allocation of responsibilities. (See Management of responsibilities map)
  • Firms must certify persons performing types of functions as fit and proper to perform the function/role under the CR. (See Certification Regime)
  • Conduct rules apply to senior managers, certified staff and other staff. (See Conduct rules)