Jurisdiction(s):
United Kingdom

UK SM&CR enforcement against Senior Managers: FCA/PRA investigations, thresholds, sanctions, settlement and practical issues

Published by a LexisNexis Financial Services expert

Practice notes

Introduction

Oversight of senior leaders across financial services underwent a dramatic overhaul when the Senior Managers and Certification Regime (SM&CR) arrived for banks in March 2016. The scope later widened to insurers in December 2018 and, from December 2019, to virtually all other financial services businesses. The regime was designed to drive a wholesale shift in compliance culture across the sector in the wake of the global financial crisis. It reinforces personal accountability at the top by enabling the Financial Conduct Authority (FCA) and/or the Prudential Regulation Authority (PRA) to more readily pursue senior managers for their firms’ shortcomings. The framework also reaches the broader workforce through the Certification Regime and the Conduct Rules, which bind all staff other than ancillary employees. For practical materials on the SM&CR, see Practice Note: Senior Managers and Certification Regime—overview; and for matters of investigations, enforcement and discipline, see Practice Note: FCA and PRA investigations, enforcement and discipline—overview...

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Web page updated on 22/05/2026

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