SMF Recruitment FAQ: Fees, Timelines, Fractional Cover and Form A

About SMF Appointments

What exactly is an SMF appointment?

An SMF, or Senior Manager Function, is a designated role under the FCA’s Senior Managers and Certification Regime that carries personal, evidenced regulatory accountability. The individual holding it is named on the FCA Register, approved before they can start, and can be held personally accountable by the FCA — separately from any action against the firm — if governance or conduct failures occur within their area of responsibility. Our SMF overview guide covers this in full.

Which designations does SMF Capital actually cover?

We cover the full range, executive and non-executive: SMF1 (Chief Executive), SMF4 (Chief Risk Officer), SMF5 (Head of Internal Audit), SMF9 (Chair), SMF10/11 (Risk and Audit Committee Chairs), SMF12 (Remuneration Committee Chair), SMF14 (Senior Independent Director), SMF16/17 (Compliance Oversight and MLRO), SMF18 (Other Overall Responsibility), SMF19/21/22 (overseas and group structures), SMF24 (Chief Operations function), and SMF27 (Partner function). Our SMF Designations index links to a detailed guide for each one.

My role doesn’t have a name I recognise — how do I know which designation applies?

This is a genuinely common starting point, not a sign you’re behind. Tell us the role’s actual reporting line, board status, and area of responsibility, and we’ll help map it to the correct designation before any search begins. Our guide to which SMFs apply at which firm tier is a useful starting reference.

Our Search Process

How is an SMF search actually different from a standard executive search?

We build the FCA’s fit and proper assessment into the process from the first conversation — testing candidates against honesty and integrity, competence and capability, and financial soundness before anyone reaches a shortlist, rather than treating it as a final compliance step. We also assess for designation-specific, sector-relevant experience rather than general seniority, since “FCA-regulated firm experience” isn’t a single, transferable credential. Our guide to the fitness and proper test in full sets out exactly what we’re testing for.

Who actually runs the search?

Every search, executive or non-executive, is overseen by Adrian Lawrence FCA and run by an experienced senior consultant from start to finish. This matters more for SMF appointments than most recruitment contexts, because judging genuine regulatory readiness depends on the same person understanding the regulatory context, the firm’s situation, and the candidate’s real fit, consistently, throughout.

Do you help with the Form A submission itself?

We don’t complete or submit Form A on a firm’s behalf — that remains the firm’s own regulatory responsibility, usually supported by internal compliance or legal advisers. What we do is build the search so the evidence base for that submission is already strong by the time an offer is made, which is why our placements consistently clear Form A without the follow-up queries that a generic search often generates. Our guide to what actually goes wrong in Form A submissions covers the most common causes of delay.

Do you recruit heads of compliance and chief compliance officers?

Yes. In most firms the head of compliance or chief compliance officer is the person approved for SMF16, and we recruit for those roles on a permanent, interim or fractional basis. See chief compliance officer and head of compliance recruitment.

Fees and Engagement

Do you work on a retained or contingent basis?

Most SMF searches — particularly non-executive and senior executive appointments — are run on a retained basis, reflecting the depth of assessment the role actually requires. For some executive and fractional/interim arrangements, a contingent structure can be appropriate. We’ll agree the right model with you at the outset, based on the designation and urgency involved.

What does an SMF search actually cost?

Fees vary by designation, firm size and regulatory complexity — there’s no single number that applies across the board. Our guide to what SMF roles actually pay in 2026 sets out current compensation benchmarks, which is usually the more useful starting point than a headline fee percentage, since search fees are typically structured around the eventual compensation package.

Timelines

How long does an SMF appointment actually take?

Realistically, six to nine months from search commencement to the individual starting in role — twelve to eighteen weeks for the search itself, plus three to six months for Form A approval once an offer is accepted. Dual-regulated firms, or candidates with a background requiring additional explanation, can take longer. Our guide to how long an SMF appointment actually takes sets out the full timeline and why boards consistently underestimate it.

We have an unplanned vacancy right now — what are our options?

The FCA’s 12-week rule allows someone to cover a Senior Manager Function without approval where the absence is temporary or reasonably unforeseen. Since the April 2026 changes, the firm has 12 weeks to submit an application for the person covering, and they can stay in post until the FCA decides. It is often the right bridge into a properly structured interim arrangement while a permanent search runs. Call us directly and tell us you’re inside an unplanned vacancy — timing is everything here, and our guide to the 12-week rule explains exactly how the window works.

Fractional and Interim Arrangements

Can we cover an SMF designation on a fractional basis rather than hiring full-time?

Yes, for several designations — SMF16 and SMF17 particularly — provided it’s genuinely proportionate to your firm’s scale and risk profile. We’ll give you an honest view on whether a fractional model fits, rather than defaulting to it because it’s cheaper. See our fractional compliance officer (SMF16) and fractional MLRO (SMF17) pages, or fractional and interim SMF cover for other functions.

Can one person be our compliance officer and MLRO on a fractional basis?

Yes, and it is the most common arrangement at smaller firms. One experienced person holds both SMF16 and SMF17 for one or two days a week, with a named alternate for suspicious activity reports on the days they are not working. See our fractional compliance officer and MLRO for small firms page and when to split a combined role.

How many days a week does a fractional compliance officer or MLRO need?

Anything from two days a month at a small, low-risk firm to two or three days a week at a growing retail or payments firm. The FCA’s test is whether the person has enough time for your firm’s risks, alongside their other appointments. Our guide to how many days a fractional MLRO or compliance officer needs explains how to size it, and can one person hold SMF16 at more than one firm? covers portfolios.

What does a fractional compliance officer or MLRO cost?

Typically £650 to £1,000 a day, often as a monthly retainer. At roughly one day a week, that is around £30,000 to £48,000 a year. Our guide to what a fractional compliance officer or MLRO costs sets out the figures with worked examples.

Is a compliance consultant the same as a fractional compliance officer?

No. A consultant advises and supports; a fractional compliance officer is approved by the FCA as your SMF16 and takes on the accountability. Our guide FCA compliance consultant or approved SMF16? explains the difference and when each makes sense.

We’re going through FCA authorisation — when should we start recruiting our SMF team?

Earlier than most firms instinctively expect — ideally before your authorisation application is drafted, not once it’s nearly ready to submit. A strong, specifically identified SMF16 and SMF17 candidate materially strengthens an application. See our SMF Authorisation Support service and our guide to the authorisation journey.

Confidentiality

Will our search be kept confidential?

Yes. Board and senior executive SMF searches are almost always run confidentially, and we don’t disclose a client’s identity to candidates, or a candidate’s details to a client, without explicit agreement at each stage. This is standard practice for the seniority of appointment we handle.

I’m a candidate — will you share my CV without asking me first?

No. We never submit your details to a client without your explicit agreement, given how sensitive many of these processes are for candidates as well as firms. See our jobs board, including compliance officer jobs and MLRO jobs, or register with us in confidence.

Which Practice Is Right for Us?

Our search doesn’t carry an SMF designation — can you still help?

We’ll say so directly and make the introduction to the right sister practice in our group: FD Capital for Finance Director and CFO recruitment, Exec Capital for C-suite and board-level search without a regulatory dimension, NED Capital for non-executive appointments at unregulated or lightly regulated firms, and Accountancy Capital for qualified finance appointments below director level.