The Senior Managers and Certification Regime (SMCR) replaced the Approved Persons Regime (APR) for solo-regulated firms from 9th December 2019. Firms with obligations under the SM&CR have until 9th December 2020 to ensure: –
- all relevant staff are trained on the Conduct Rules and how they apply to their roles
- all staff in certified roles are fit and proper to perform that role and are issued with a certificate
- they submit data to the FCA for the directory of key people working in financial services.
Owing to the disruption of Covid-19, in June the Treasury delayed this deadline to 31st March 2021 to allow an extra 4 months for firms to assess the fitness and propriety of their Certified Staff. This delay aims to give firms affected by the coronavirus pandemic more time to develop and implement the changes required under the regime.
To ensure consistency among other SM&CR deadlines, the FCA is currently consulting on extending the deadline for the below requirements from 9th December 2020 to 31st March 2021: –
- the date the Conduct Rules come into force
- the deadline for submission of information about Directory Persons to the FS Register
- changing references in the rules to the deadline for assessing Certified Persons as fit and proper
Firms are reminded however that if they are able to assess and certify staff, they should do so as early as possible. The FCA have advised that they will still publish details of certified employees of solo firms starting from 9th December 2020 on the FS Register.
If you are looking for help assessing the fitness and propriety of employees; training staff in the conduct rules; carrying out due diligence on staff performing SMF roles or require policy templates for any of the SMCR requirements; our SMCR Document Pack is already being used by hundreds of regulated firms to hit the ground running .