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Implementing the Senior Managers and Certification Regime

14 January 2020
The Senior Managers and Certification Regime ('SM&CR') came into effect on 9 December 2019. DWF recently hosted a round table event to discuss implementation issues with a range of firms in the finance and insurance industries.

The topics that were discussed at our round table event included:

  • The Senior Managers Regime - Senior Management Functions, Prescribed Responsibilities, and navigating any last-minute issues;
  • The practicalities of implementing each aspect of the SM&CR and whether firms understood the ongoing requirements, including Reasonable Steps expectations and future regulatory 'housekeeping';
  • The Certification Regime: Fitness and propriety; and
  • The Conduct Rules and what happens next and when?

Download the white paper to read about the experiences and views of firms who have recently implemented the new regime

How we can help

We have assisted many firms with the implementation of the SM&CR and continue to support those firms in their post implementation plans and transitional arrangements. Our ongoing service includes:

Post implementation evaluation

Our post implementation evaluation provides assurance that your firm is compliant with the requirements of the SM&CR in accordance with the FCA's Senior Management Arrangements, Systems and Controls ("SYSC") sourcebook. This involves reviewing your firm's processes, procedures and documentation against regulatory requirements, identifying any material gaps and providing recommendations to address them.

Certification & Conduct rules evidence

Firms are required to be able to meet all evidential requirements before 9 December 2020 and we can provide an expert view on how firms can approach meeting these requirements, including how to tailor existing processes (such as the appraisals) to be able to meet the competence assessment requirements and evidential standards.


All firms must ensure that training has been provided to all employees in respect of the Conduct Rules, with an annual refresher where necessary, by 9 December 2020. Our conduct rules training has been designed to be as straightforward as possible, and tailored for all levels of staff within your firm. We have four training modules depending on whether you.

Contact us to find out more