SM&CR MISCONCEPTIONS: The Certification Regime is easy to implement

Oct 7th '19

Assuming you have done all you need for the Senior Managers Regime on 9th December 2019. You have identified those impacted, and they are all ready, you’ve even got a project plan for ongoing compliance oversight and monitoring of the new regime.


It might feel like plain sailing from now, but with the excitement of activity to implement the Senior Managers Regime as part of SM&CR before the implementation deadline, take care not to fall into the trap of missing the all-important Certification Regime.


  • Senior Managers are the ones executing the key roles requiring FCA approval, so there’s no more to get done.

Not really. The Certified population could be considerably larger in most firms, so there is far more to work on. You are obligated to check and certify that they are fit and proper to perform their role and provide Conduct Rules training in advance of the implementation date of 9th December 2019. Additionally, embedding this cultural change, specifically with lots of people, could take much endeavour and time.


  • Right, but we’ve got another 12 months after the implementation date for Senior Managers, so we’ll just take care of it then.

Not exactly! While firms have 1 year from the start of the new regime to certify individuals that are performing a Certification Function, they must still identify them by the first day. You will also need to ensure you have collected all extra evidence that will allow you to assess an individual’s fitness and propriety prior to 9th December 2020. As all of us know, in the realm of regulation, a year is not a long time! Your solution is to start thinking about it now, alongside the Senior Managers Regime.


  • This sounds very complex.

It doesn’t have to be, although you do need to be mindful of the different facets of SM&CR implementation, in addition to training that will need to be tailored for every role.


  • This is a big job, it’s really going to take a considerable amount of planning, resource and time!

It may do, so you’d be smart to consider this. But don’t worry, we could be there to help plan, communicate and support your implementation, including the training you may need to get the Certification Regime implemented correctly and on schedule.


Even when you’re already well underway, we can still help provide you with the assurance you need to become confident all bases are covered.


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