14 July 2026 · 5 min read
The Senior Managers and Certification Regime is not a one-off form-filling exercise. It is a live map of who is accountable for what, and it needs to change whenever your firm does.
Statements of responsibility should be readable
A statement of responsibility that simply restates the FCA's prescribed responsibilities tells a supervisor nothing. Describe what the individual actually decides, what they oversee, and where their remit ends.
Fitness and propriety is annual, and evidenced
Certification staff must be assessed at least once a year. Keep the criminal records checks, credit checks, regulatory references and competence assessments together, dated, and signed off by a named senior manager.
Governance evidence: the pack, the minutes, the follow-up
Supervisors look for board and compliance committee packs, minutes showing genuine challenge, and an action log that closes items. If your minutes only record decisions and never the debate, they will be read as a rubber stamp.
