Jurisdiction(s):
United Kingdom

UK FCA/PRA SM&CR interviews for SMF approval: when used, focus areas, preparation guidance, including dual-regulated firms

Published by a LexisNexis Financial Services expert

Practice notes

SM&CR—SMF interviews for regulatory approval

This Practice Note sets out how the Financial Conduct Authority (FCA) and/or the Prudential Regulatory Authority (PRA) may deploy interviews as part of the approval process for those seeking to perform senior manager functions (SMFs) at authorised firms under the UK regulators’ Senior Managers & Certification Regime (SM&CR). It confirms that interviews are a discretionary tool within the SMF approval pathway and highlights when SMF candidates are most likely to be asked to attend. It also offers practical guidance for SMF candidates and their firms on preparing for interview, including frequent areas of focus, how the regulators approach external versus internal candidates, and additional points for candidates at dual-regulated firms.

This Practice Note should be read together with:

SM&CR Checklist—preparing for SMF interviews, which provides a practical framework to support candidates and firms in preparing across different SMF roles
SM&CR Checklist—SMF approvals: what to do when things go wrong, which helps candidates and firms identify, manage and respond to issues arising during or following an SMF interview, on receipt of a ‘minded to refuse’ letter, or where the

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Billy Bradley

CMS

Billy has significant contentious regulatory experience and advises financial services firms and senior individuals on governance, individual accountability and regulatory risk, with a particular focus on the Senior Managers & Certification Regime (SMCR). He regularly advises on Conduct Rule breaches, fitness and propriety assessments, regulatory references and non-routine individual approval applications. Billy frequently engages with the FCA and PRA on behalf of clients, including responding to detailed regulatory information requests and preparing senior individuals for SMF interviews. Billy has extensive experience supporting firms in the design, implementation and operation of the SMCR, including accountability mapping, governance frameworks and the practical application of individual accountability requirements at senior management and board level. He also advises clients on FCA enforcement investigations, disciplinary proceedings, market abuse matters and whistleblowing investigations, as well as self-notification obligations arising from potential regulatory breaches. Billy supports clients in managing complex and...

Hannah Manning

CMS

Hannah is an Associate in the Financial Services Regulatory team at CMS, with expertise spanning both contentious and advisory aspects of financial services regulation. She delivers strategic advice to firms and individuals on a broad range of regulatory matters, including governance, conduct, and market abuse issues. Hannah has significant experience guiding clients through complex FCA and PRA interactions, from supervisory enquiries to enforcement investigations and proceedings before the Upper Tribunal. A core area of Hannah’s practice is the Senior Managers and Certification Regime. She advises on the practical implementation of the regime and supports clients throughout the Senior Management Functions (SMF) application process. Hannah assists with internal investigations and regulatory notifications involving Senior Managers, providing strategic guidance on accountability and individual conduct risk....

Faye Ellis

CMS

Faye is an Associate in the Financial Services Regulatory team at CMS. She possesses broad experience related to both contentious and non-contentious matters, advising a wide range of solo-regulated market participants. During her career to date, she has completed secondments to one of the UK’s largest consumer banks, a global asset management firm and a major online payment platform. Each secondment has given her a unique insight into how the Senior Management and Certification Regime operates in practice, providing her with the ability to give strategic guidance on the application process and implementation throughout the SMCR journey....

Web page updated on 27/05/2026

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