The Other SMCR Notification Forms: B, C, D and E Explained

Form A gets almost all the attention in SMF recruitment conversations, and rightly so — it’s the form that gets an individual approved in the first place. But the SMCR’s notification framework doesn’t stop once someone starts in role. Forms B through E cover everything that happens afterwards: withdrawals, certification, ongoing changes, and departures. Understanding what each one actually does matters for any firm managing an SMF population beyond the point of initial appointment. For Form A itself, our sister practice Exec Capital’s Knowledge Centre covers it in detail, and our own guide to common Form A mistakes covers the practical pitfalls — we won’t repeat either here.

Form B: Withdrawing an Application

Form B is used to withdraw a Form A application that’s already been submitted but not yet determined — most commonly where a candidate withdraws from a role during the approval process, or where a firm decides not to proceed with an appointment while the FCA is still considering it. Filing Form B promptly when a candidate situation changes matters because leaving a live application pending unnecessarily can create confusion in the firm’s regulatory record and, in some cases, draw supervisory queries the firm would rather avoid.

Form C: Ceasing to Perform a Controlled Function

Form C notifies the FCA that an individual has stopped performing an SMF, whether through resignation, retirement, redundancy, or any other reason. This needs to be filed within a set period of the individual ceasing to perform the function, and it’s a notification firms sometimes deprioritise in the operational scramble of a departure — particularly an unplanned one — even though the FCA treats timely notification as a genuine compliance obligation, not an administrative afterthought. A firm that’s slow or inconsistent in filing Form C creates a gap between its actual management structure and what the FCA Register shows, which is precisely the kind of discrepancy that draws supervisory attention.

Form D: Notification of Changes

Form D is the workhorse of ongoing SMCR compliance — used to notify the FCA of a wide range of changes to an existing SMF holder’s circumstances or responsibilities, including material changes to their Statement of Responsibilities, changes to their personal circumstances that could affect their fitness and propriety, and various other events the FCA’s rules specify. Because Form D covers such a broad range of triggers, firms need a genuinely reliable internal process for identifying when a Form D notification is actually required — a change that seems purely administrative from inside the firm, such as a reporting line adjustment that alters an SMF holder’s real scope of responsibility, can trigger a notification obligation that’s easy to miss without a deliberate review process built around it.

The most commonly missed trigger

The single most commonly missed Form D trigger is a material change to an SMF holder’s Statement of Responsibilities that happens gradually, through a series of smaller adjustments to their role over time, none of which individually seemed to cross the threshold requiring notification. Firms that review Statements of Responsibilities only when a new appointment is made, rather than periodically for existing SMF holders, are the ones most likely to have accumulated an unnotified material change without realising it.

Form E: Internal Transfer of an Approved Person

Form E is used specifically when an individual already approved to perform an SMF at one firm within a group moves to perform an SMF at another firm within the same group, allowing a more streamlined notification process than a fresh Form A submission from scratch. This form has real practical value for group structures making internal senior management moves, but it’s only available where the individual is moving between firms within the same group — a move to an unconnected firm, even where the individual is already FCA-approved elsewhere, still requires a full Form A application.

Why Getting This Right Matters Beyond Simple Compliance

The FCA Register is a live, publicly accessible record of who holds which SMF at which firm, and it’s used by counterparties, investors, and the regulator itself as a genuine source of truth about a firm’s senior management structure. A firm with a poorly maintained notification history — late Form C filings, missed Form D triggers, inconsistent record-keeping — is signalling something about the overall discipline of its governance function, independent of whether any individual notification failure is serious in isolation. Firms that treat the full notification lifecycle, not just the initial Form A, as an ongoing operational discipline consistently present as more credible to supervisors than those that treat SMCR compliance as a one-off event at the point of appointment.

What This Means for a Firm Managing an Existing SMF Population

Beyond the recruitment process itself, firms benefit from a periodic review of their SMF holders’ actual, current responsibilities against what’s on file with the FCA — checking specifically for accumulated changes that should have triggered a Form D, departures that weren’t followed by a timely Form C, and any group restructuring that might have called for a Form E rather than a fresh Form A. This kind of review sits naturally alongside the Responsibilities Map review we recommend for Enhanced tier firms, since both exercises are, in substance, checking whether the firm’s documented governance structure still matches reality.