The UK's Senior Managers and Certification Regime (SMCR) is entering a new chapter - one that promises greater operational flexibility for firms while keeping the fundamental pillars of accountability firmly intact.
According to StarCompliance, the Financial Conduct Authority's Phase 1 reforms have given the industry a clearer picture of where the regime is heading, even as broader structural changes remain a work in progress.
StarCompliance recently discussed SMCR's next chapter, and what the FCA changes mean for firms.
The stated aim of Phase 1 is to cut duplication, sharpen regulatory expectations, and ease certain administrative processes - all without diluting the standards that have defined SMCR since its introduction. Most of the changes took effect on 24 April 2026, with further updates coming on 10 July 2026 and again on 1 September 2026. That final tranche of changes specifically concerns non-financial misconduct within financial services, an area regulators have increasingly turned their attention to.
Among the practical changes: streamlined certification for individuals with overlapping roles, revised guidance on conduct breaches and regulatory references, and more flexibility in how Statements of Responsibilities and FCA Directory submissions are handled. Taken together, these updates are designed to reduce the administrative load on compliance teams - but they do not represent a softening of the underlying rules.
Firms that interpret greater flexibility as reduced obligation may find themselves on the wrong side of a regulatory conversation. Responsibility Maps and Statements of Responsibilities must continue to be treated as living documents. Certification and Fitness & Propriety records must remain accurate, properly documented, and auditable. The expectation to monitor conduct rules, track breaches, oversee training, and demonstrate reasonable steps at every level of the organisation has not changed. If anything, the move towards more flexible submission arrangements reinforces the need for centralised, reliable systems of record - ones capable of withstanding scrutiny at short notice.
Looking further ahead, Phase 2 discussions are under way around more fundamental changes to SMCR, including reducing the number of roles requiring regulatory pre-approval, overhauling or scrapping the Certification Regime entirely, and replacing the FCA Directory with a leaner alternative. However, any such changes would require HM Treasury legislation, and mid-2027 remains the most optimistic timeline currently on the table. Firms operating on manual processes or fragmented documentation structures cannot afford to wait.
StarCompliance, which provides purpose-built compliance technology commonly known as Star, has positioned its SMCR capabilities to help firms navigate both the current framework and whatever follows. Its platform centralises certification and Fitness & Propriety records, maintains Responsibility Maps and Statements of Responsibilities, and supports regulatory reference and conduct breach documentation. It also aligns data with FCA submission formats and automates attestations, training workflows, and breach tracking - all while maintaining the audit trails that regulators expect. Beyond the UK, Star's individual accountability capabilities extend to frameworks in Ireland, Singapore, and Australia.
The direction of SMCR reform is becoming clearer, but the destination remains some distance away. Firms that build scalable, centralised governance processes now will be far better placed to adapt as further changes emerge - rather than scrambling to catch up when they do.
Read the full StarCompliance post here.