SMCR Conduct Rules Training

Treasury Extends Deadline

With the Treasury and FCA extensions from 9 December 2020 until 31 March 2021 for the deadline of the fitness and propriety assessments of Certified Persons, the date the Conduct Rules come into force and the deadline for submission of information about Directory Persons to the Register; firms have been given 3 extra months to develop and implement effective and compliant Conduct Rules training.

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The Conduct Rules themselves are standard; how firms train their staff however, varies greatly from company to company, which is why we have included extensive guidance on developing compliant, adequate training sessions in our SMCR Document Pack as oppose to trying to provide a generic training session.

Whilst it may be possible to provide a pre-written training session on acting with integrity or due care, skill and diligence; it is not possible to relate this to a business and its employees from a generic template. When it comes to training individuals or senior managers in the Conduct Rules, one size definately does not fit all!

Some important information to remember when developng your Conduct Rules training program are: –

  • Start by identifying any ‘ancillary staff’ to whom the Conduct Rules do not apply and will therefore not be required to undergo the mandatory training
  • Identify who requires just the Individual Conduct Rules training (tier 1) and who will also need the tier 2, Senior Manager Conduct Rules training
  • Remember that the Conduct Rules apply to both a firm’s regulated and unregulated financial services activities
  • Understand the general limitations that apply to the Conduct Rules
  • Rules such as ‘acting with integrity’ or ‘acting with due care’ can be ambiguous and construed in different ways by different employees


If you have not yet developed your SMCR Conduct Rules training program or still need to implement SMCR policies and templates for areas such as fitness and propriety assessments, SMF due diligence and questionnaires, Statement of Responsibility, Responsibilities Map, CF Certificate and other mandatory SM&CR documents; join the hundreds of firms already using our market leading SMCR Document Pack.

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