FCA Senior Managers (SMCR)
When the FCA asks — be ready to answer personally.
I was in every oversight committee. I challenged the MI. I escalated when I should have. But my Statement of Responsibilities describes my role — not what I actually did. If the FCA opens an investigation, I am reconstructing from memory.
That gap between what you know you did and what you can prove, in a structured form, at speed, is the enforcement exposure SMCR was designed to surface.
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The regulatory landscape
The Senior Managers and Certification Regime places personal accountability at the heart of FCA regulation. Every FCA-regulated firm must designate Senior Managers who are personally responsible for specific areas of the business. The Duty of Responsibility means that when something goes wrong in a Senior Manager's area, the FCA will ask what that individual personally did to prevent it.
PS25/23, effective 1 September 2026, extends the Conduct Rules to cover non-financial misconduct across all 37,000 non-bank SMCR firms. Senior Managers are expected to take reasonable steps to prevent and address bullying, harassment and violence in the workplace. Failing to do so may amount to a breach of Conduct Rule 2. The FCA has confirmed its supervisory focus will now turn to how firms are tackling this in practice.
Consumer Duty, in force since July 2023, requires firms to demonstrate — not just assert — that they are delivering good outcomes for retail customers. The Consumer Duty Board Report is due 31 July 2026. The FCA's evidential expectations are hardening: the question is no longer whether you have a Consumer Duty framework but whether you can prove it is working.
The Certification Regime requires annual fitness and propriety assessments for all certified staff. The assessment itself must be evidenced — not just the resulting certificate.
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What regulators look for
The FCA's enforcement approach under SMCR focuses on individual accountability. Investigators will ask what you personally knew, what you personally did, and when. They will review your Statement of Responsibilities, your delegation records, and the oversight actions you took in your area. They will look for contemporaneous evidence — records made at the time, not reconstructed after the fact.
Common triggers for enforcement include: failure to take reasonable steps in your area of responsibility, delegation without adequate ongoing oversight, Consumer Duty monitoring that is described in policy but not evidenced through action, and certification decisions that cannot be supported by documented assessment.
The FCA does not give advance notice of enforcement investigations. The ability to produce a structured, chronological record of your oversight actions quickly is not just operationally useful — it demonstrates the governance posture that reduces enforcement risk. Firms that the FCA describes as "demonstrably seeking to do the right thing" will benefit from less intensive supervision.
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What Evidentia gives you
Reasonable steps evidence
Every oversight action, committee attendance, escalation and challenge recorded at the moment it happens — mapped to your Statement of Responsibilities. When the FCA asks what you personally did, you open Evidentia and produce your answer.
PS25/23 readiness
A structured record of every non-financial misconduct step you take — investigation initiated, reasonable steps documented, outcome recorded. Built for the 1 September 2026 deadline from day one.
Consumer Duty monitoring trail
Not just a Consumer Duty policy — a dated, sealed record of every monitoring action you took, every data point reviewed, every decision made. The evidence the FCA is increasingly asking to see.
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The evidence gap
Most Senior Managers we speak to know exactly what they have done. They attended the right committees. They asked the right questions. They escalated when they should have. But their evidence of this is scattered across meeting minutes written by someone else, emails that would take days to compile, and memory.
The FCA does not investigate what you intended to do. It investigates what you can prove you did. For most Senior Managers, the honest answer is that reconstruction would take days and the result would still not be contemporaneous evidence.
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Key enforcement facts
PS25/23 applies to 37,000 non-bank firms from 1 September 2026. No transitional period.
The FCA has confirmed its focus will now turn to how firms are tackling non-financial misconduct in practice — supervisory scrutiny begins immediately.
Consumer Duty Board Reports are due 31 July 2026. The FCA's evidential expectations are hardening from assertion to proof.
Find out whether your current approach would withstand scrutiny.
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