SM&CR Phase 2: PRA CP14/26 Proposals, Responses Due 22 January 2027

On 22 October 2026 the Prudential Regulation Authority published CP14/26, its SM&CR Phase 2 consultation, and the Financial Conduct Authority published its companion paper CP26/37 the same day. The PRA proposes to remove regulatory pre-approval for almost half of the current Senior Manager Functions (SMFs), to drop the requirements to assess, certify and seek regulatory references for the roughly 7,700 people in its Certification Regime, and to stop routine resubmission of Statements of Responsibilities (SoRs) and Management Responsibilities Maps (MRMs). Responses are due by 22 January 2027.

For the teams that prepare SMF applications, Form J updates, annual certificates and Form L breach notifications, the CP proposes a change to each of those submissions. None of it applies yet. The PRA says significant elements depend on Parliament enacting the Financial Services and Markets Bill 2026 (the FSM Bill) substantially in its current form, and it expects implementation in the second half of 2027, after HM Treasury commences the relevant provisions. Until then the Phase 1 rules in PS12/26, in force since 24 April 2026, remain the baseline.

Related reading: SM&CR Reforms 2026: What the New Rules Mean for Firms

SM&CR Phase 2 timeline: from PS12/26 to an H2 2027 start

The CP sits between a Phase 1 that is already in force and a Phase 2 that cannot start until Parliament acts. These are the dates that matter for planning.

The sequencing in paragraph 2.3 of the CP is the part to put in the diary. The PRA proposes to make its rule, supervisory statement and statement of policy changes once the relevant FSM Bill provisions have received Royal Assent and been commenced, but before those provisions take effect, and it understands that HM Treasury intends to allow an appropriate implementation period when it commences them. The CP gives no calendar date for the PRA policy statement. Q1 asks what implementation period respondents consider appropriate after it is published, and the PRA records that its Practitioner Panel favoured a short period and changes introduced together instead of piecemeal.

Between now and implementation the current regime runs unchanged. Every SMF appointment still needs regulatory pre-approval, subject to the 12-week rule for temporary or reasonably unforeseen vacancies. Certified staff still need their fitness and propriety (F&P) assessment and certificate on appointment and annually. The PS12/26 expectation that firms generally submit updated SoRs and MRMs no later than six months after a significant change in responsibilities still applies.

Why the FSM Bill decides how much of CP14/26 can happen

Large parts of the SM&CR sit in the Financial Services and Markets Act 2000 (FSMA), which is why Phase 1 stayed narrow: PS12/26 says its scope largely reflected constraints imposed by FSMA. HM Treasury’s consultation response, updated on 22 April 2026, set out the legislative package that would open up Phase 2. It would remove the Certification Regime from primary legislation, give the regulators a power to specify roles where a firm notifies an appointment after its own F&P assessment, repeal the prescriptive statutory provisions on SoRs, repeal the statutory requirements on firms to notify conduct breaches and to run mandatory Conduct Rules training, and let the regulators accept applications subject to time limits or conditions without triggering statutory notice requirements. Separately, the Treasury proposed to cut the regulators’ statutory deadline for determining senior manager applications from three months to two.

CP14/26 maps its proposals onto specific FSMA provisions. The table below shows the ones the CP names.

Appendix 6 to the CP marks five proposals as subject to legislative amendment: notified SMFs, the section 55M route to require pre-approval, time-limited and conditional approvals without a statutory notice, the removal of certification requirements, and the change to conduct breach notification. The CP still presents the whole package with a single expected implementation date in paragraph 2.22, and the draft rules sit in one proposed instrument, the Senior Managers Regime (Amendment) Instrument 2027 in Appendix 1.

Notified SMFs: which roles keep pre-approval

For a notified role, the regulator’s assessment before appointment falls away and the F&P decision rests with the firm. The firm assesses the candidate and, once it has determined that the successful candidate is fit and proper, submits a notification to the regulators before the start date. The CP proposes that notifications may be submitted up to three months before the individual’s start date, that a notification takes effect on the later of the start date the firm specifies and the regulator’s acknowledgement of receipt, and that a firm may withdraw a notification before it takes effect. On that wording, a start date that falls before the acknowledgement does not bring the effective date forward. Under the FSM Bill as brought from the House of Lords, a firm would withdraw a notification by written notice to the regulator, and only with the consent of the notified person and, where different, the person who is to retain them to perform the function (proposed new FSMA section 60ZA(5)).

The PRA expects notifications to be materially simpler than applications. Firms would generally provide details of the proposed notified SMF holder, confirmation that the F&P assessment and supporting checks have been completed, and SoRs and MRMs where applicable, and the PRA does not currently intend to ask for other supporting documents. The forms and information requirements themselves would be set in a PRA direction, which the PRA intends to publish with the policy statement.

The accountability attached to the role stays the same under either route. The PRA intends to hold notified SMF holders to exactly the same standards as pre-approved ones, including the Duty of Responsibility, the requirement to take reasonable steps and the Senior Manager Conduct Rules. To anchor the firm’s new gatekeeping role, it proposes to clarify that Prescribed Responsibility A (the firm’s performance of its obligations under the Senior Managers Regime) also covers the firm’s vetting of candidates for senior management functions, with supporting guidance in SS28/15 and SS35/15.

Table 1 of the CP applies the split to all firms. The PRA weighed the nature of each function and its inherent responsibilities, evidence from its own SMF assessments, whether the function is mandatory, whether it is an executive or an oversight role, and feedback from its Practitioner Panel. It anticipates that SMF application volumes would fall by more than 40%.

The PRA’s own headline examples of roles moving to notification are Chief Actuaries and the Chairs of the Risk and Audit Committees. The Chair of the Governing Body (SMF9) stays pre-approved, and so does SMF24, where the PRA points to operational risks, including those arising from artificial intelligence and cyber incidents. Insurance teams should read the bottom of the table with care: the actuarial functions move to notification, while the Small Insurer Function (SMF25) and the Head of Small Run Off Firm (SMF26) remain pre-approved.

SMF7 splits into SMF7 and SMF7a

The Group Entity Senior Manager function would divide into an approved SMF7 and a notified SMF7a, and the PRA says the overall SMF7 population would not grow. An individual who performs a group-level role and exercises significant influence would need pre-approval where that group role corresponds to certain proposed PRA and FCA pre-approved functions. The CP names the most relevant: Group Chief Executive, Chief Financial Officer, Chief Risk Officer, Chief Operations Officer, Chief Compliance Officer, Money Laundering Reporting Officer and Board Chair. All other SMF7s would become notified. Firms would have to classify on the substance of the group role, and the individual’s job title would not settle it.

The CP says SMF7s in branches or subsidiaries of overseas banks may be likely to meet the SMF7a criteria and so need only a notification. Appendix 4 also updates SS5/21, the PRA’s supervisory statement on international banks. The SM&CR changes sit apart from branch financial reporting, which our PRA Branch Return guide for UK bank branches covers.

Pre-approval can return in exceptional cases

Notified status is the default for the roles in Table 1, but the PRA could override it for a particular firm. Using its existing powers under section 55M FSMA, the PRA could require a firm to apply for pre-approval for one notified role or for all of them. The CP describes this as an exceptional-circumstances tool and gives three examples: a firm at risk of failing; serious concerns about a firm’s governance or its ability to assess the F&P of notified SMFs; and a notified role of particular importance to a given firm’s safety and soundness. In limited circumstances, the PRA may also use section 55M ahead of implementation, telling affected firms that they would need to apply for pre-approval for some or all notified roles instead of moving to notification.

For roles that remain pre-approved, the PRA expects firms to obtain approval before announcing an appointment. Announcing “subject to regulatory approval” is for limited cases, such as a market disclosure duty around an urgent change of Chair or CEO, or an appointment linked to a time-sensitive change in control. Even then, the firm should make every effort to discuss the appointment with the PRA before any announcement, consistent with Fundamental Rule 7. The CP’s draft amendments would set the expectation out in a new paragraph 2.4D of both SS28/15 and SS35/15.

SoRs, MRMs and Prescribed Responsibilities: fewer submissions, same upkeep

Today a firm resubmits a Senior Manager’s SoR, with the MRM where applicable, after a significant change in responsibilities, using Form J when there is no SMF application. Phase 1 set a general expectation of submission no later than six months after the change. CP14/26 proposes to end that event-driven submission.

The PRA would no longer require SoRs and MRMs to be submitted whenever they significantly change, Form J would be removed, and any SoR or MRM the PRA requests outside an application or notification would go directly to the firm’s supervisory contacts. SoRs and MRMs would still accompany SMF applications and notifications where required, showing the planned arrangements once approval is granted or the notification takes effect. The PRA estimates around 1,700 fewer submissions a year, the same number as the Form Js it currently receives outside SMF applications.

The maintenance duty stays. Firms would still have to keep SoRs and MRMs up to date internally and be able to provide them to the PRA on request. One of the CP’s alignment changes alters the cadence for insurers: the insurance Allocation of Responsibilities Part currently requires an MRM update at least quarterly or after certain significant events, while the banking Part requires the MRM to be kept up to date at all times. Under the CP, firms would need to keep the MRM up to date at all times. The CP would also specify the content of SoRs in rules and use a single Glossary definition of “senior management regime” across all Parts.

Proposal 7 removes several Prescribed Responsibilities (PRs): those relating to the Certification Regime and PR allocation; those on training and induction of governing body members, senior management and key function holders (as applicable); the PR for the MRM, given the scope of PR A; and the PR for maintaining the firm’s business model, given the inherent responsibilities of the Chief Executive Function (SMF1). Re-mapping responsibilities after those deletions would not on its own trigger an SoR submission, since the PRA says it does not intend firms to submit SoRs solely because they are updated as a result of implementing the proposals. Firms would still have to keep them current.

Firms with a single Senior Manager

Proposal 9 removes the requirement to maintain SoRs and MRMs at firms with a single Senior Manager holding one or more SMFs, on the basis that all relevant responsibilities sit with that person. Eligibility turns on a counting rule. A Senior Manager who is temporarily absent still counts. So does a person who is not a Senior Manager of the firm but is covering for someone who has permanently ceased to be one, and a Senior Manager who provides that cover personally counts twice.

On those rules, a firm with one Senior Manager in post and an interim appointee covering a second, departed Senior Manager counts two, and keeps its SoR and MRM obligations while the cover lasts. The PRA’s direction would explain how the exemption interacts with the SoRs and MRMs submitted with an application or notification.

Temporary SMF cover: the proposed 18-week period and the Form D change for long absences

Phase 1 changed the 12-week rule so that a firm covering a temporary or reasonably unforeseen SMF vacancy has up to 12 weeks to submit a complete application, instead of needing a determination within that period. CP14/26 renames it the Temporary SMF cover rule and proposes, jointly with the FCA, to extend the temporary cover period from 12 to 18 weeks. The extension comes with conditions attached. The PRA expects the longer period to be used only where there is a clear justification, the “temporary” or “reasonably unforeseeable” absence requirements continue to apply to PRA functions at dual-regulated firms, and firms are still expected to submit any required application or notification as soon as possible. New guidance in SS28/15 and SS35/15 would set expectations on documenting the arrangement between the firm and the person providing cover.

The Form D change is narrower than its headline. The PRA proposes to stop requiring a Form D notification when a PRA-approved person will be temporarily absent for more than 12 weeks, and when that person returns. Form D itself, used for changes to personal information and application details and for conduct breaches or disciplinary action, appears on the CP’s list of forms to be amended. Firms should still make their supervisory contact aware of temporary or unforeseen absences through the usual engagement lines.

Time-limited and conditional approvals

At present, a time limit or condition attached to an SMF approval brings statutory notice requirements with it, including where the firm itself wanted the limit or condition. Using the power the FSM Bill would create, the PRA proposes “permitted conditional applications”: a firm applying for a pre-approved SMF could request a time limit or condition without that notice process. Time-limited requests could be made in a wide range of circumstances, and SoP4/15 would list indicative cases where a time limit is more or less likely to be appropriate, including short-term vacancies in pre-approved roles and scenarios the extended cover rule does not reach.

Conditions are drawn far more tightly, because the PRA is concerned they could be used to approve people who otherwise fail minimum F&P standards. The CP identifies one circumstance only: a candidate reducing or ceasing certain activities, for example a Chair (SMF9) resigning non-executive directorships that exceed the maximum allowed under PRA rules. Requests would accompany the SMF application with a clear rationale explaining how the condition or time limit addresses whatever would otherwise prevent an unconditional approval. The PRA expects such requests to be rare and encourages firms to discuss them first. Q8 asks whether other conditions should be permitted.

Leaving the Certification Regime: what the competent employee rule would carry

The FSM Bill would, if implemented as proposed, remove the statutory basis for the Certification Regime and leave the regulators to decide whether successor measures are needed. The PRA concluded that a successor regime would impose disproportionate costs. It proposes to remove the requirements to assess F&P and issue certificates on recruitment and annually, and to seek regulatory references, for those formerly in scope of the PRA Certification Regime, around 7,700 individuals. In 2025 the PRA counted around 2,400 certificates issued to newly certified individuals.

The replacement is an extension of a rule firms already apply. The “competent employee” rule in the General Organisational Requirements Part (2.1A(2)) and the Conditions Governing Business Part (2A.1(5)) requires firms to employ personnel with the skills, knowledge and expertise needed for the responsibilities allocated to them. The CP would extend it to personal characteristics, including integrity and honesty. Where CRR firms and Solvency II firms employ people in functions previously subject to certification, they would need to take reasonable steps to assess whether those individuals show the integrity, honesty and other characteristics their roles require.

The proposed rules call these functions “Competence and Integrity Functions”. For CRR firms they cover material risk takers (MRTs) other than Senior Managers. For Solvency II firms they cover MRTs and key function holders who are not Senior Managers. Both are established categories in the PRA Rulebook, the CP proposes no change to either, and the PRA notes that firms already have processes for identifying who falls within them.

The obligation is ongoing, but the PRA expects it to be considered at recruitment and again where there is reasonable cause to reconsider whether it is being met. High-level guidance would go into SS28/15 and SS35/15.

Some obligations outlast the certificate. The three Individual Conduct Rules the PRA applies to certified persons would continue to apply to key function holders, MRTs and certain senior roles at credit unions. On the Senior Manager side, the PRA keeps F&P requirements for SMFs and other key senior individuals, and its cost table carries the annual re-assessment of SMF fitness and propriety at an unchanged cost. Dual-regulated firms also run FCA certification functions: the FCA’s CP26/37 proposes removing its Certification Regime as well and retiring the Directory of certified and assessed persons, and the FCA asks dual-regulated firms to read CP14/26 alongside it. For an EU comparison, our article on the CSSF fit and proper declaration covers the forms Luxembourg credit institutions file when they appoint key function holders.

Form L after Phase 2: a higher threshold for former certified staff only

Form L is how firms tell the PRA about conduct rule breaches by certified persons, notified non-executive directors (NEDs) and individuals covering under the 12-week rule, where the breach leads to “disciplinary action” as defined in section 64C FSMA: a formal written warning, suspension or dismissal, or reduction or recovery of remuneration. Section 64C is due to be repealed by the FSM Bill, so the PRA proposes to bring the definition into its Glossary under a new name, “disciplinary or remuneration action”.

For individuals in roles previously within the Certification Regime, the reporting trigger would move from a formal written warning to a final written warning, after completion of any appeals process within the internal investigation. Breaches resulting in suspension, dismissal or reduction or recovery of remuneration would still be reportable, and Form L would still be submitted within seven business days.

The higher threshold stops at the former certification population. Reporting for people subject to the Senior Manager Conduct Rules stays as it is: SMFs, those performing SMF roles under the Temporary SMF cover rule, and Conduct Rule NEDs (the proposed new name for notified NEDs). Fundamental Rule 7 is untouched as well. The PRA says the proposal is not intended to undermine a firm’s duty to disclose anything of which the PRA would reasonably expect notice, including suspected or actual conduct breaches.

Forms the PRA would amend or delete

Appendix 7 lists the forms affected. The PRA intends to take references to certain forms out of the Rulebook so that it can make minor changes, such as contact details, explanatory text or layout, without consulting on rule changes. The application and notification forms would be specified in a PRA direction, published with the policy statement and not included in this consultation. The PRA says it does not plan to add questions, require extra supporting documents or widen the information firms must provide, and would consider further consultation if substantive changes proved necessary.

Firms keep the underlying duty when Form M goes. Notified NEDs would become Conduct Rule NEDs, and firms would still have to ensure they are fit and proper; only the notification to the regulator ends. Form F carries group changes such as a global CEO based outside the UK or an individual with purely strategic responsibility for UK operations. The PRA notes that this update can be provided outside the form, through FCA Handbook submission requirements and supervisory engagement, which is the basis for dropping the Form F requirement.

Some of the changes need no rule at all. The PRA intends to cut material submitted with pre-approval applications, for example the summary of handover material and a separate organisational chart, which should already be in the MRM. The Financial Services Register would distinguish notified from pre-approved SMFs, with details to follow closer to implementation.

Transition: pending applications, existing approvals and unfinished certifications

Proposal 12 and Chapter 4 set out the switchover:

• Up to one month before the implementation date, firms could submit notifications for roles becoming notified, with a start date on or after implementation, so appointees can start on or shortly after that date.
• The PRA would keep accepting pre-approval applications for those roles until the implementation date. Applications submitted before then but not yet determined would continue to be assessed under the existing framework.
• From implementation, firms would notify for those roles.
• Existing approvals carry over. A person already approved for a function that becomes notified needs no notification, and SMF7 approvals granted before implementation would cover both SMF7 and SMF7a afterwards.
• Certification assessments and regulatory reference requests still under way at implementation would not need to be completed, though firms could finish them voluntarily where lawful and appropriate.

The second bullet leaves one practical question open. An application lodged shortly before implementation for a role that is about to become notified stays in the existing process until it is determined. The CP does not say whether a firm could withdraw such an application and notify once notification is available, which makes it a point for firms with appointments planned around the implementation date to raise under Q9.

Reading the cost-benefit numbers in CP14/26

The cost-benefit analysis covers around 1,200 PRA-authorised firms subject to the SM&CR, including around 675 deposit takers and 560 insurance firms. Between 1 March 2025 and 28 February 2026 the PRA determined 1,250 SMF applications, and there are around 7,000 SMF holders in total. The baseline assumes the regime is unchanged, with anything removed from legislation recreated in PRA rules and Phase 1 implemented. Against it, the PRA estimates:

The central case takes annual SM&CR costs across affected firms from £24.8 million to £13.3 million, a reduction of about 47%. The split matters more than the headline. Ending certification accounts for just over half of the quantified saving, while notification is worth £313,000 a year on these numbers. The PRA says the broader benefits it expects from notification, namely the speed, flexibility and predictability of appointments, are not captured in the estimates, and it judges that its unquantified benefits may be at least as significant for firms as the quantified savings. The estimates rest on a joint PRA and FCA survey run in June and July 2026 plus an earlier pilot, 96 responses from dual-regulated firms in total, and the PRA cautions that the sample overrepresents banks and building societies and underrepresents credit unions and insurers.

The PRA is open about the trade-off. It states that the proposals represent some increase in prudential risk, which it considers proportional to the benefits, and it lists the mitigants it relies on: the Conduct Rules, the extended competent employee rule, and its ability to require pre-approval for a notified role. It also says the reforms bring the UK closer to similar regimes in other countries, without naming them. Australia’s Financial Accountability Regime is one accountability regime with proposed 2026 rule changes of its own, covered in our APRA and ASIC FAR rule changes article.

How to respond to CP14/26 by 22 January 2027

The PRA invites responses by 22 January 2027 and gives CP14_26@bankofengland.co.uk as the address for comments and enquiries. Chapter 8 adds three administrative points.

Respondents should state whether they consent to the PRA publishing their name or their organisation’s name in its summary of responses, and whether they are responding as an individual or for an organisation. The PRA asks respondents to say whether any proposal is likely to affect people who share protected characteristics under the Equality Act 2010, and which groups. And responses may be shared with the Bank of England, the FCA and HM Treasury. The FCA collects responses to CP26/37 through its own online form with the same closing date, so a dual-regulated firm answering both regulators files two responses.

Q1, Q7 and Q9 are the questions where a firm’s own records carry most weight, because they turn on appointment pipelines, how long cover arrangements actually run, and how much system change a switchover needs. Q13 is open-ended. The PRA lists divergences its draft rules would already close, such as aligning at six years the period of overseas work that triggers a request for the fullest available information on SMF and notified NED candidates (the Large Non-Solvency II Firms Fitness and Propriety Part currently says five), and invites firms to name others.

Frequently Asked Questions

Will regulatory references still be needed for Senior Manager candidates?

The removal proposal in Chapter 4 covers regulatory references for individuals formerly in scope of the Certification Regime, and the CP’s cost table carries regulatory references for SMFs at an unchanged annual cost. The CP does not describe separately how references fit the notification route, beyond the expectation that a notification confirms the F&P assessment and supporting checks are complete. The PRA direction published with the policy statement is where that detail would appear.

Does the PRA consultation change the FCA Directory?

CP14/26 does not mention the Directory of certified and assessed persons, which is an FCA requirement. The FCA’s CP26/37 proposes to retire it. A dual-regulated firm’s Directory obligations therefore follow the FCA’s final rules, which the FCA expects to publish in a policy statement in the first half of 2027.

Could the PRA still take enforcement action against someone who used to be certified?

Yes. The CP says the PRA will continue to be able to take individual enforcement action against this population, in addition to the relevant firm, where necessary to advance its primary objectives, and firms remain accountable for applying the relevant requirements to them.

Will the regime be renamed once certification goes?

Not in this consultation. The PRA acknowledges that removing the Certification Regime may make the name “Senior Managers and Certification Regime” outdated, and says it may consider renaming the regime in future.

Does CP14/26 shorten the deadline for the PRA to decide an SMF application?

The statutory deadline is a matter for legislation. HM Treasury proposed to shorten the regulators’ statutory deadline for determining senior manager applications from three months to two months, and the CP presents its proposals as complementing that change. The PRA reports that in the latest reporting quarter 98% of senior manager applications were determined within the proposed two-month deadline.

Will a credit union have any pre-approved SMFs after Phase 2?

Not by default. The Credit Union Manager function (SMF8) is the only SMF that PRA rules require credit unions to have, and the CP proposes to make it notified. The PRA notes this would make credit unions the only firm type with no SMF subject to pre-approval, unless a credit union voluntarily appoints someone to a pre-approved SMF role.

Does Table 1 cover FCA-designated Senior Manager Functions?

Table 1 lists the PRA’s proposed split. The FCA sets out its own approach to notified roles and to removing certain SMFs in CP26/37. The two regimes meet in the SMF7 test, which refers to group roles corresponding to proposed PRA and FCA pre-approved functions, including the Chief Compliance Officer and the Money Laundering Reporting Officer.

Related Articles

• SM&CR Reforms 2026: What the New Rules Mean for Firms: the Phase 1 changes the PRA (PS12/26) and FCA (PS26/6) published on 22 April 2026.
• PRA Branch Return: Half-Yearly Reporting for UK Bank Branches: the return UK branches of international banks file with the PRA.
• APRA and ASIC FAR Rule Changes 2026: What ADIs, Insurers and RSE Licensees Must Update: Australia’s accountability regime and the rule changes APRA and ASIC proposed in 2026.
• CSSF Fit and Proper Declaration: Revised Forms Apply From 15 October: the Luxembourg appointment forms for management body members and key function holders.
• PRA Threshold Indexation: How CP13/26 Moves 128 Thresholds: the PRA’s other October 2026 consultation, on indexing Rulebook thresholds to nominal GDP.

Key Takeaways

• Run SM&CR on the PS12/26 rules until the PRA’s final Phase 2 rules take effect; CP14/26 contains no relief that applies before the implementation date.
• Classify every SMF holder, vacancy and planned appointment against Table 1 before answering Q2 and Q3, sorting SMF7s by the substance of the group role.
• Plan for fewer SoR and MRM submissions and unchanged upkeep; under the proposed insurance rules, MRMs would move from a quarterly update to up to date at all times.
• Rebuild certification workflows at CRR and Solvency II firms around the competence and integrity assessment for MRTs and, at Solvency II firms, non-SMF key function holders, checked at recruitment and when there is reasonable cause.
• Re-map form-driven tooling for the proposals: Forms F, J and M would be deleted, Forms D and L would change, and form requirements would move into a PRA direction.
• Once implemented, the proposed final-written-warning threshold would apply to former certified roles only; SMF, temporary cover and Conduct Rule NED reporting would stay unchanged.
• Diary 22 January 2027 for two responses, one addressed to CP14_26@bankofengland.co.uk and one through the FCA form for CP26/37.

Sources and References

• PRA, CP14/26: Review of the Senior Managers and Certification Regime (SM&CR), Phase 2 (22 October 2026): bankofengland.co.uk
• PRA, CP14/26 Appendix 1: Draft PRA Rulebook: CRR Firms, Non-CRR Firms, Solvency II Firms and Non-Solvency II Firms: Senior Managers Regime (Amendment) Instrument 2027: cp1426app1.pdf
• PRA, CP14/26 Appendix 6: Summary of SM&CR Phase 2 proposals: cp1426app6.pdf
• PRA, CP14/26 Appendix 7: Overview of impacted forms (application and notification): cp1426app7.pdf
• PRA, PS12/26: Review of the Senior Managers and Certification Regime (SM&CR), Phase 1 (22 April 2026): bankofengland.co.uk
• FCA, CP26/37: Senior Managers and Certification Regime (SM&CR) Review: Phase 2 (22 October 2026): fca.org.uk
• FCA, PS26/6: Senior Managers and Certification Regime review: fca.org.uk
• HM Treasury, Reforming the Senior Managers & Certification Regime: Consultation Response (updated 22 April 2026): gov.uk
• UK Parliament, Financial Services and Markets Act 2000, section 55M (PRA requirements): legislation.gov.uk
• UK Parliament, Financial Services and Markets Act 2000, section 59 (approval for controlled functions): legislation.gov.uk
• UK Parliament, Financial Services and Markets Act 2000, section 62A (statements of responsibilities): legislation.gov.uk
• UK Parliament, Financial Services and Markets Act 2000, section 64B (conduct rules: notification and training): legislation.gov.uk
• UK Parliament, Financial Services and Markets Act 2000, section 64C (disciplinary action): legislation.gov.uk
• UK Parliament, Financial Services and Markets Bill [HL], Bill 152 2026-27 (as brought from the House of Lords), proposed new FSMA section 60ZA (notifications under section 59): publications.parliament.uk

Before 22 January 2027: the SMF map and the response file

Two artefacts carry most of the work before the consultation closes. The first is an SMF map: every current holder, vacancy and planned appointment classified against Table 1, SMF7s sorted by the substance of their group role, and any appointment expected near the H2 2027 implementation window flagged for the transitional rules. The second is the response itself, answering the questions where the firm holds evidence, stating its publication consent, and addressed to CP14_26@bankofengland.co.uk by 22 January 2027, with the FCA response on CP26/37 filed by the same date.

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