Around 139,000 people working below senior-manager level in UK financial services would no longer face annual certification checks or appear on the Financial Services Register under proposals published on 22 October 2026. The Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA) said the changes to the Senior Managers and Certification Regime (SM&CR) are expected to save firms around £2bn over a 10-year period.
- Estimated saving for firms2 £bn over 10 years
- Staff leaving the Certification Regimearound 139,000 people
- Expected cut in PRA pre-approvals43 %
- Consultations close22 January 2027
- FCA final rules expectedfirst half of 2027
What changes and what stays
| Measure | Under the proposals |
|---|---|
| Certification Regime and annual checks for around 139,000 staff | Removed |
| Pre-approval for roles such as Chief Actuaries | Replaced by notification to regulators |
| FCA Directory of certified and assessed persons | Retired |
| Conduct-rule breach reporting threshold for most staff | Raised |
| Ongoing filing of responsibility statements and maps | Ended |
| Pre-approval with fit and proper tests for CEOs, CFOs and Chairs | Kept |
| Pre-approval for notified roles in high-risk cases | Regulators can still require it |
| Firms' responsibility for staff competence and conduct | Kept |
| Accountability for roles moved to notification | Unchanged |
Source: Bank of England / PRA and FCA, 22 October 2026, 22 October 2026.
“These proposals keep checks in place for the most important roles, meaning individuals are accountable for their actions, but reduce the administrative burden where it isn't needed, giving firms more time to invest in growth-focused activities and greater flexibility in onboarding senior talent.”
Some of the changes need new law. The FCA said the Financial Services and Markets Bill would remove many prescriptive SM&CR requirements from legislation and leave regulators to decide how they apply. The regulators said consulting now would let them implement the reforms quickly once legislation is passed. The PRA said its reforms would halve the overall burden of its part of the regime. For FCA Enhanced solo-regulated firms, around 15% of applications would move to notification and two senior-manager roles would be removed. The regulators announced the plans alongside Mansion House speeches by Braddick and FCA chief executive Nikhil Rathi.
SM&CR has applied to the banking sector since 2016 and was later extended across financial services. The first phase of reforms took effect in April 2026, including a 30% increase in the size thresholds that decide which firms count as Enhanced firms. The PRA's consultation is CP14/26 and the FCA's is CP26/37.
- Bank of England / PRA, Regulators unveil plans to simplify Senior Manager and Certification Regime, 22 Oct 2026, 22:00 CEST
- FCA, CP26/37: Senior Managers and Certification Regime (SM&CR) Review: Phase 2, 22 Oct 2026, 02:00 CEST
- FCA, Executive committees (Nikhil Rathi, chief executive; Sarah Pritchard, deputy chief executive), 2 Oct 2026, 02:00 CEST