FCA PS26/6 Publishes First Phase SM&CR Reforms Reducing Firm Burden
Summary
The FCA has published PS26/6, implementing Phase 1 reforms to the Senior Managers and Certification Regime. Most changes take effect on 24 April 2026, reducing burden on solo-regulated and dual-regulated firms through targeted measures on criminal record checks, the 12-week rule, SMF 7 and SMF 18 functions, statements of responsibilities, certification requirements, the Directory of certified persons, regulatory references, Conduct Rules, prescribed responsibilities, and enhanced firm thresholds. Regulatory reporting and process improvements apply from 10 July 2026, while changes aligned to PS25/23 on non-financial misconduct take effect from 1 September 2026.
“Most changes take effect on 24 April 2026, so firms can benefit from them straight away.”
Solo-regulated firms that have not yet begun SM&CR gap analysis ahead of the 24 April 2026 effective date should prioritise that work now — the window is approximately two months. Dual-regulated firms additionally need to review the PRA's parallel PS12/26 to avoid inconsistent implementation across dual obligations.
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What changed
PS26/6 introduces the first phase of SM&CR reforms, targeting efficiency and proportionality while preserving individual accountability. The reforms cover nine areas: criminal record checks, the 12-week rule, SMF 7 (group entity senior managers) and SMF 18 (other overall responsibility functions), statements of responsibilities and management responsibilities maps, the Certification Regime, the Directory of certified and assessed persons, regulatory references, Conduct Rules, prescribed responsibilities, and thresholds for enhanced SM&CR firms. Most provisions take effect on 24 April 2026.
Solo-regulated and dual-regulated firms already in SM&CR scope, including third country branches, must update their SM&CR policies, procedures, and governance frameworks. Dual-regulated firms should also review the PRA's parallel Policy Statement PS12/26 for a complete picture. Firms should track three phased deadlines: 24 April 2026 (most changes), 10 July 2026 (regulatory reporting improvements), and 1 September 2026 (non-financial misconduct alignment). The FCA expects a second phase of broader reforms later in 2026 contingent on Treasury legislative changes.
What to do next
- Firms should review PS26/6 to identify which SM&CR changes apply to their operations
- Most changes take effect on 24 April 2026
- Regulatory reporting improvements apply from 10 July 2026
- Changes aligned to PS25/23 on non-financial misconduct apply from 1 September 2026
Archived snapshot
Apr 22, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
PS26/6: Senior Managers and Certification Regime review
Consultation opened 15/07/2025 Consultation closed 07/10/2025 Policy Statement published 22/04/2026 22/04/2026
Consultation papers First published:
21/04/2026
Last updated: 22/04/2026
We set out changes for the Senior Managers and Certification Regime (SM&CR) as part of the first phase of reforms.
Why we are changing
We want to make the regime more efficient and proportionate while maintaining strong individual accountability.
Phase 1 brings in targeted measures to reduce unnecessary burden for firms, including on:
- Criminal record checks and disclosure.
- 12-week rule.
- SMF 7 (group entity senior managers) and SMF 18 (other overall responsibility functions).
- Statements of responsibilities and management responsibilities maps.
- Certification Regime.
- Directory of certified and assessed persons.
- Regulatory references.
- Conduct Rules.
- Prescribed responsibilities.
- Thresholds for becoming an ‘enhanced’ SM&CR firm.
Who this is for
- All solo-regulated and dual-regulated firms already in scope of the SM&CR. This includes third country branches.
- Dual-regulated firms should read it alongside the PRA’s Policy Statement.
Next steps
Most changes take effect on 24 April 2026, so firms can benefit from them straight away.
Improvements to regulatory reporting and processes will apply from 10 July 2026. This gives firms and us time to make changes to processes and procedures.
Changes made to align with PS25/23: ‘Tackling non-financial misconduct in financial services’, apply from 1 September 2026.
If the Treasury’s proposed changes proceed, we expect to consult on a second phase of broader reforms later in 2026.
Dual-regulated firms should also review the PRA’s Policy Statement to gain a complete understanding of all the changes to the SM&CR that apply to them.
Background
We consulted on changes in CP25/21 in July 2025, in parallel with the PRA (CP18/25).
The SM&CR seeks to reduce harm to consumers and strengthen the functioning of the market by making sure financial services professionals:
- Are individually accountable to their employers and to the regulators.
- Meet expected standards of conduct. It is set out in the Financial Services and Markets Act 2000 (FSMA) and implemented through the FCA Handbook and through PRA rules for dual-regulated firms.
Page updates
06/01/2026
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CP25/21: Senior Managers and Certification Regime review DP23/3: Review of the Senior Managers and Certification Regime (SM&CR) Senior Managers Regime How we assess senior management function applications Directory of certified and assessed persons
PRA: PS12/26: Review of the Senior Managers and Certification Regime PRA: CP18/25 – Review of the Senior Managers and Certification Regime
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