What a Responsibilities Map Is

A Responsibilities Map is a document that describes a firm’s management and governance arrangements, including its reporting lines, its Senior Managers and how responsibilities are allocated between them. Under the Senior Managers and Certification Regime, Enhanced firms must maintain one, and the FCA’s requirements are in SYSC 25. It must be kept up to date and be consistent with each Senior Manager’s Statement of Responsibilities.

Core firms don’t have to keep one, but many find a simple version useful, especially if they’re approaching the Enhanced threshold. Our guide to the Responsibilities Map explains the requirement in more detail.

What’s in the Template

How to Build the Map

Start With the Business, Not the People

List every business area, activity and management function first: products, distribution channels, operations, technology, finance, HR and so on. Then allocate overall responsibility for each to a Senior Manager. Starting with the people tends to leave gaps where nobody’s job title obviously fits.

Allocate Every Prescribed Responsibility

Use the regulators’ wording and check which Prescribed Responsibilities apply to your firm. The template includes example rows for responsibilities most Enhanced firms will have, but the full list depends on your permissions and whether you’re dual-regulated.

Explain the Governance

Describe the board, its committees and the matters reserved to the board. The regulator wants to understand how decisions are actually made, not just who holds which title.

Cover Group Arrangements

If group companies provide services or take decisions affecting the firm, explain how, and which UK Senior Manager oversees them. Our article on group SMF roles covers when group executives need approval themselves.

Using the Map to Find Gaps

Once drafted, test the map with three questions:

• Is there any business area, activity or function without a Senior Manager with overall responsibility?
• Is any Prescribed Responsibility unallocated, or allocated to someone without the time or expertise?
• Do any responsibilities overlap without a clear explanation of how they’re divided?

Gaps often mean a new appointment, most commonly a chief risk officer, chief operating officer, committee chair or SMF18 holder for a business head. Our page on becoming an Enhanced firm sets out the hires firms typically need.

A Simple Example

Consider a mid-size investment manager that has just become Enhanced. Its draft map lists five business areas: portfolio management, distribution, operations, technology and finance. Allocating overall responsibility shows that the chief executive covers portfolio management and distribution, the finance director covers finance and operations, but nobody has overall responsibility for technology, which is run by a head of IT reporting to the chief operating officer of the parent group. The map also shows that the Prescribed Responsibility for the firm’s financial crime policies is allocated to the compliance officer, who is already stretched as both SMF16 and SMF17.

Two decisions follow. The firm appoints a UK chief operating officer to hold SMF24 with overall responsibility for operations and technology, and it reallocates the financial crime Prescribed Responsibility to the chief executive, with the MLRO reporting to him on it. Without the map, neither gap would have been obvious until the regulator asked.

Common Mistakes

• Organisation charts instead of maps. A chart shows reporting lines, not accountability.
• Unallocated areas, particularly support functions such as HR, technology and outsourcing.
• Inconsistency with Statements of Responsibilities.
• Out of date after departures, restructures or acquisitions.
• Group arrangements left unexplained.

Keeping It Up to Date

The map must be updated whenever responsibilities change: a Senior Manager joins or leaves, the firm restructures, it acquires a business or changes its group arrangements. Use the change log in the template to record every update and its approval. Review it at least annually alongside the board’s governance review. A map that’s accurate on the day of approval but out of date six months later gives the regulator a misleading picture, so the update process matters as much as the first draft.

Handover Procedures

Enhanced firms must also have procedures for handing over responsibilities when Senior Managers change. The template includes a section to reference your handover policy and record recent handovers. Our SMF succession planning template helps plan for those changes in advance.

Using the Map When Recruiting

The map is also one of the best tools for recruitment. It shows exactly which responsibilities a new Senior Manager will hold, and how their role fits with everyone else’s. We start every Senior Manager search from the Statement of Responsibilities and, at Enhanced firms, from the map. That’s how we make sure candidates are matched to the accountability they’ll actually carry.

Who Should Own the Map

Most firms give ownership of the Responsibilities Map to the company secretary or the compliance function, with the chief executive and chair responsible for making sure it reflects how the firm really works. The board should approve it, and the Senior Manager responsible for the firm’s obligations under the Senior Managers regime should make sure it’s kept current. Whoever owns it, the content has to come from the business: a map written by compliance alone, without the input of the Senior Managers it describes, tends to describe how the firm is meant to work rather than how it does.

Frequently Asked Questions

Do Core firms need a Responsibilities Map?

No, it’s an Enhanced firm requirement. But a simple map is useful for any firm, and essential preparation if you’re approaching the Enhanced threshold.

Do we send the map to the FCA?

Firms must maintain it and be able to provide it to the regulator. Check the current rules for any submission requirements, for example with approval applications.

How often should it be updated?

Whenever responsibilities change, and at least annually as part of a governance review.

Is the template free?

Yes. Download it and adapt it for use within your firm. It’s general guidance, not legal or regulatory advice.