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

The Forms at a Glance

Forms are submitted through FCA Connect. For dual-regulated firms, the PRA’s requirements apply alongside the FCA’s. The rules are in SUP 10C, and the FCA’s SMCR pages link to the current forms. For Form A itself, see what goes wrong in Form A submissions.

Form B: Withdrawing an Application

Form B withdraws a Form A that has been submitted but not yet decided. The usual reasons are a candidate pulling out during the approval period, a firm deciding not to proceed, or a firm choosing to withdraw rather than risk a refusal. That last case matters. A refusal is a formal decision that stays on the record and has to be disclosed in future applications. A withdrawal is not a refusal, though the regulator keeps its own record of why. If the case officer signals serious concerns, take advice quickly. Our guide to refused or withdrawn applications explains the options.

File Form B promptly once the decision is made. Leaving an application live when the candidate has gone wastes the regulator’s time and creates confusion in the firm’s record.

Form C: When a Senior Manager Leaves

Form C tells the regulator someone has stopped performing an SMF, whether through resignation, retirement, redundancy, dismissal or a change of role. It is due within seven business days. Firms often let it slip in the scramble of an unplanned departure, but it is a real obligation. A late Form C leaves a gap between who actually runs the firm and what the FCA Register shows.

Qualified Form C

If the firm knows of anything that suggests the departing person may not be fit and proper, such as a conduct breach, disciplinary action or an investigation, it must say so on the Form C. This is sometimes called a qualified Form C. It must be accurate and fair, because it follows the individual. The same facts will usually need to appear in any regulatory reference the firm later gives; see regulatory references explained.

Plan the replacement at the same time

A departure leaves a gap. Responsibilities must be reallocated, the responsibilities map updated and, often, temporary cover arranged under the 12-week rule. Since April 2026, firms have 12 weeks to submit an application for the permanent replacement. Our guides to urgent SMF replacement and what to do when your MLRO resigns cover the first weeks.

Form D: Changes to an Approved Person

Form D covers changes to an approved person’s details, such as name or contact details, and, more importantly, any matter that could affect their fitness and propriety. Examples include a criminal charge or conviction, a civil judgment, bankruptcy or an individual voluntary arrangement, disqualification as a director, or disciplinary action by a professional body. Fitness matters must be notified as soon as the firm becomes aware of them; the firm doesn’t wait for the annual assessment.

Firms need a reliable way to find out. That means a clear duty on Senior Managers to tell the firm promptly, an annual attestation, and periodic checks such as credit and directorship searches. See the fit and proper test and SMCR background checks.

Statements of Responsibilities and Responsibilities Maps

A material change to a Senior Manager’s responsibilities requires a revised Statement of Responsibilities and, at Enhanced firms, an updated responsibilities map. Since the April 2026 reforms, firms still have to update these documents internally as soon as a significant change happens, but they can submit revisions to the FCA in batches up to every six months, sending only the latest version.

The most commonly missed change is the gradual one. A Senior Manager’s role grows through a series of small adjustments, none of which seems significant on its own, until the Statement of Responsibilities no longer describes what they actually do. Firms that only review Statements when someone new is appointed are the ones that discover this during a supervisory visit. Review them at least annually. See writing a Statement of Responsibilities and the responsibilities map explained.

Form E: Moving Within a Group

Form E is used when someone already approved for an SMF at one group firm moves to an SMF at another firm in the same group. It is shorter than a full Form A, though the regulator still assesses the person for the new role. It only applies within a group as the rules define it; a move to an unconnected firm needs a full Form A even if the person is already approved elsewhere. The 2026 reforms help here too: criminal record checks are no longer needed for internal and intra-group moves. Our guide to SMF approval for groups covers the wider picture.

Other Notifications That Sit Alongside the Forms

• Conduct Rules breaches: disciplinary action against a Senior Manager for a Conduct Rules breach must be notified promptly; breaches by other staff are reported annually. Since April 2026 a breach already reported under SUP 15 doesn’t need reporting again. See the Conduct Rules.
• Breaches under the 12-week rule: must be reported as soon as practicable; for PRA firms, on Form L.
• FCA Directory: details of certified staff and directors. Since the reforms, most updates are due within 20 working days rather than seven, but leavers must still be reported within seven. See the Certification Regime.

Why This Matters Beyond Compliance

The FCA Register is a public record used by counterparties, investors and the regulator. A firm with late Form Cs, missed Form Ds and out-of-date Statements of Responsibilities is signalling something about the discipline of its governance, whatever the seriousness of each lapse. Firms that treat notifications as a routine part of governance, not a task triggered only by a new appointment, look more credible to supervisors.

A simple calendar helps: Form C on every departure, Form D on every relevant change, Statements and maps reviewed at least annually and submitted in batches, and Directory updates within the new deadlines. Someone needs to own it, usually the compliance officer or company secretary.

Frequently Asked Questions

When must a Form C be submitted?

Within seven business days of the person ceasing to perform the Senior Manager Function.

What is a qualified Form C?

A Form C that tells the regulator about matters suggesting the departing person may not be fit and proper, such as disciplinary action or a conduct breach.

Is withdrawing an application the same as a refusal?

No. A refusal is a formal decision that must be disclosed in future applications. A withdrawal is not, although the regulator keeps a record.

Do we need to submit every change to a Statement of Responsibilities straight away?

Since April 2026, firms must update the document internally when a significant change happens but can submit revisions to the FCA in batches up to every six months.

When can we use Form E?

When someone already approved at one group firm moves to an SMF at another firm in the same group.