The SMCR Responsibilities Map Explained

What the Responsibilities Map Actually Is

The Responsibilities Map is a single, comprehensive, firm-wide document describing the entire management and governance structure of an Enhanced tier firm — every SMF holder, every key committee, every reporting line, and how they all connect. Where a Statement of Responsibilities is written from one individual’s perspective, the Responsibilities Map is written from the firm’s perspective: it’s the document a supervisor, or an incoming senior manager, would read to understand how accountability is actually distributed across the whole organisation, not just within one role.

Firms required to maintain a Responsibilities Map must keep it comprehensive and current at all times — not as an annual compliance exercise, but as a living document that’s updated whenever the firm’s management structure genuinely changes. An SMF holder typically carries a specific Prescribed Responsibility for ensuring the Map is kept up to date, which means responsibility for its accuracy is itself a named, individual accountability under the regime.

What the Map Must Contain

The rules are in the FCA Handbook at SYSC 25. In practice, a compliant map usually covers:

Our free Responsibilities Map template gives a ready structure to work from.

How It Differs From a Statement of Responsibilities

Why the Map Matters More Than Its Administrative Reputation Suggests

Both the Responsibilities Map and individual Statements of Responsibilities are treated by the FCA and PRA as significant supervisory and enforcement tools, not paperwork. When something goes wrong at a firm, these documents are what regulators use to establish who was actually responsible for the area where the failure occurred. A Map that’s vague, outdated, or doesn’t genuinely reflect how the firm operates in practice undermines the ability of both the firm and its individual SMF holders to demonstrate, after the fact, that accountability was properly allocated — which matters enormously if the Duty of Responsibility is ever invoked.

Where Firms Get This Wrong

Treating it as a static document

The most common failure is producing a Responsibilities Map when a firm first reaches Enhanced tier status, and then failing to update it as the business genuinely evolves — new committees formed, reporting lines changed, SMF holders replaced. A Map that reflects the firm’s structure from two years ago is not compliant simply because it was accurate once; the requirement is that it stays comprehensive and current at all times.

Gaps and overlaps that mirror real organisational confusion

A well-constructed Map should reveal, and force resolution of, any genuine gaps or overlaps in the firm’s actual management structure — situations where two SMF holders both believe they own a particular area, or where no one does. Firms sometimes produce a Map that papers over this ambiguity with vague drafting rather than using the exercise to force a genuine resolution of who is actually accountable for what. This defeats the purpose of the document and leaves the underlying organisational confusion fully intact.

Disconnection from individual Statements of Responsibilities

The Responsibilities Map and the individual Statements of Responsibilities beneath it need to be internally consistent — every accountability described in an SMF holder’s Statement of Responsibilities should be reflected accurately in the firm-wide Map, and vice versa. Firms that draft these documents separately, without cross-checking them against each other, frequently end up with inconsistencies that create exactly the kind of confusion the framework is designed to prevent.

Keeping the Map Up to Date

The map needs updating whenever the structure changes, not just once a year. Common triggers include:

Firms that are unsure whether their map still reflects reality can use our governance and SMF structure review, which checks the map against the Statements of Responsibilities and how the business actually runs.

What This Means for Recruitment

When we’re briefed on an SMF search at an Enhanced tier firm, reviewing the firm’s current Responsibilities Map — not just the specific role’s draft Statement of Responsibilities — tells us a great deal about how genuinely well-organised the firm’s governance actually is. A firm with a clear, current, internally consistent Map is one where a new SMF holder can understand their own accountability with real precision from day one. A firm with a vague or outdated Map is one where an incoming SMF holder may be inheriting ambiguity that predates their appointment, which is worth surfacing and addressing before the individual starts, not after.

Every new appointment also changes the map, so we agree the draft Statement of Responsibilities for the role with the firm before the search starts. Firms filling several roles at once, often when they first become Enhanced, can use our multi-SMF team build, and our guide to becoming an Enhanced firm explains what changes.

Frequently Asked Questions

Which firms need a Responsibilities Map?

Enhanced firms under the FCA solo-regulated regime, and dual-regulated firms such as banks and insurers. Core and Limited Scope firms do not.

Is the Responsibilities Map sent to the FCA?

Not routinely, but the firm must be able to provide it promptly on request, and it is often asked for during supervision or after an incident.

Who is responsible for keeping it up to date?

The firm, with a named Senior Manager usually accountable for it through a Prescribed Responsibility.

How often should it be updated?

Whenever the structure changes, and reviewed at least annually as a check.