SMF Recruitment Market Update
Our regular view of the Senior Manager recruitment market, drawn from the searches we run, the enquiries we receive and the conversations we have with firms and candidates every week. It covers which Senior Manager Functions are in demand, what is driving hiring, where candidates are scarce and what that means for firms planning an appointment. We update this page every quarter. This edition covers autumn 2026.
The Headlines
- Fractional control functions are the fastest-growing area. Smaller firms increasingly want an approved compliance officer and MLRO for two or three days a week rather than a full-time hire.
- Payments, e-money and crypto-asset firms remain the busiest sector. Authorisation, remediation and growth are all creating demand for compliance and financial crime leaders.
- Overseas firms are building UK branch teams. We are seeing more enquiries for branch heads and branch compliance officers from overseas insurers and financial groups.
- Approvability is the scarce quality. There are plenty of capable compliance professionals; there are far fewer who have already held an SMF and can show the regulator they are ready.
- The offer-to-approval gap is where hires are lost. Counter-offers during the regulatory wait remain the most common reason a successful search fails at the last stage.
Demand by Function
| Function | Demand | What we’re seeing |
|---|---|---|
| SMF16 Compliance Oversight | Very high | Steady permanent demand, plus strong growth in part-time and fractional roles at Core firms |
| SMF17 MLRO | Very high | Often combined with SMF16 at smaller firms; specialist MLROs in demand in payments and crypto-assets |
| Financial crime leadership | High | Deputy MLROs, heads of transaction monitoring and sanctions leads, often on an interim basis for remediation |
| SMF2 Chief Finance | Moderate | Driven by firms moving into the Enhanced tier and by insurers and investment firms replacing retiring CFOs |
| SMF1 Chief Executive | Moderate | Confidential successions and newly authorised firms; retained search the norm |
| SMF9–SMF14 Chairs and committee chairs | Moderate | Boards strengthening independence and skills, often prompted by succession or regulatory feedback |
| SMF19 Head of Third Country Branch | Rising | Overseas insurers and banks building or strengthening UK branches |
| SMF24 Chief Operations | Steady | Operational resilience and outsourcing oversight keep the role prominent at Enhanced firms |
What Is Driving Hiring
New authorisations
Firms seeking authorisation, particularly payment and e-money institutions and cryptoasset businesses, need to name approvable Senior Managers in their applications. The FCA expects those people to be in place, competent and adequately resourced from the start, not recruited after authorisation. See building an SMF team from scratch and the people an EMI or payment institution needs.
The cryptoasset regime
With the FCA’s new rules for cryptoasset firms now published, crypto businesses preparing for authorisation under the new regime are competing for a small pool of compliance and financial crime leaders with relevant experience. Our page on crypto-asset SMF recruitment covers the roles involved, and the finance talent gap looks at the finance side.
Supervisory pressure and remediation
Supervisory reviews and skilled person reviews continue to generate demand for interim compliance and financial crime leaders, and sometimes for permanent replacements. See staffing a section 166 remediation.
Consumer Duty
The Consumer Duty has raised expectations of compliance officers, board champions and the management information boards receive. Firms that struggled to evidence outcomes are strengthening their compliance leadership. See our Consumer Duty guide for Senior Managers.
Changes to the SMCR itself
Following the regulators’ 2025 consultations on streamlining the Senior Managers and Certification Regime, firms are watching for changes to approval processes and the Certification Regime. Until changes take effect, the current rules apply in full, and firms should plan appointments on that basis. We will cover the detail as rules are finalised; the FCA’s SMCR pages are the definitive source.
Where Candidates Are Scarce
| Scarce profile | Why | What firms can do |
|---|---|---|
| Approved SMF16/SMF17 holders willing to work fractionally | The best are already committed to two or three firms | Move quickly and be flexible on days and location |
| Financial crime leaders with crypto-asset experience | The sector is young and the pool small | Consider strong payments or e-money candidates and invest in onboarding |
| Branch heads with UK Senior Manager experience | Few people have run a UK branch for an overseas group | Start early and consider strengthening the branch compliance team instead |
| Insurance CFOs and actuarial leaders | Solvency II experience is specialist | Allow realistic timescales and benchmark pay carefully |
| First-time SMFs who are genuinely ready | Firms want experience, so few people get their first approval | Look at deputies with a strong record; see hiring your first Senior Manager |
Pay and Offers
Pay pressure is greatest where candidates are scarcest: approved compliance and financial crime leaders, particularly in payments and crypto-assets, and fractional SMF holders, whose day rates reflect demand. Buy-outs of deferred bonuses are increasingly part of senior offers. Our salary guide sets out current ranges, and what SMF roles actually pay looks at the drivers. For offer structure, see buy-outs, notice periods and clawback.
Advice for Firms Planning an SMF Appointment
- Plan for approval time from the start. The search is often the quicker part. See how long an SMF appointment takes.
- Get the designation right first. Confirm which function the role is before you advertise; see SMF designations.
- Protect the gap between offer and approval. Keep candidates engaged and deal with buy-outs early; see managing the gap.
- Consider fractional and interim options. They can cover a vacancy or suit a smaller firm permanently; see fractional and interim cover.
- Plan succession before you need it. Our succession planning template helps boards identify gaps early.
For Candidates
For experienced Senior Managers, particularly compliance officers and MLROs, the market is favourable. Fractional and portfolio careers are increasingly viable, and firms are more open to hybrid working than before; see remote and hybrid Senior Managers. For those seeking a first SMF role, the key is evidence: deputising, board exposure and direct regulatory contact. Current roles are on our jobs page, and you can register with us via our candidates page.
Sector Snapshot
| Sector | Current picture |
|---|---|
| Payments and fintech | Busiest sector: authorisation, safeguarding and financial crime leadership |
| Crypto-assets | Preparing for the new regime; very small pool of experienced leaders |
| Wealth management | Steady demand for SMF16/17, often fractional at smaller firms; Consumer Duty a key driver |
| Insurance | Overseas insurers building UK branches; CFO and actuarial roles hard to fill |
| Consumer credit | Compliance leadership strengthening around affordability, vulnerability and Consumer Duty |
| Banks and building societies | Board and committee chair succession; dual-regulated approvals remain the longest |
The Regional Picture
London remains the centre of the SMF market, but the share of searches outside London continues to grow, helped by hybrid working. We see steady demand in Edinburgh, particularly from asset managers, insurers and fintechs; in Birmingham and the Midlands, from consumer credit and financial services firms; and in Bristol and the South West. Fractional Senior Managers increasingly work across regions, combining roles at firms in different cities.
Firms outside London sometimes assume they must pay London rates to attract approved Senior Managers. That is true for the scarcest profiles, but for many roles a well-structured hybrid arrangement, with clear expectations about time in the office, widens the pool more effectively than salary alone.
SMF Recruitment
Permanent, retained, interim and fractional Senior Manager appointments. Every SMF search is led personally by Adrian Lawrence FCA
Control Functions
Compliance, MLRO and financial crime.
→ Compliance officer (SMF16)
→ MLRO (SMF17)
Board and Executive
Retained leadership search.
→ Retained executive search
→ CFO (SMF2)
Flexible Cover
Interim and fractional.
→ Fractional and interim cover
→ Fractional or full-time?
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
How often is this update published?
Every quarter. We update this page rather than publishing a new one, so the link always shows the latest view.
Where does the information come from?
From our own searches, client enquiries and conversations with candidates. It is a practitioner’s view of the market, not a statistical survey.
Can I quote this update?
Yes, with a link back to this page.
Can you give us a market view for a specific role?
Yes. We can give you a view on candidate availability, pay and timescales for any Senior Manager role before you start a search.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices, including FD Capital. He leads every SMF Capital search personally. View Adrian’s ICAEW profile.
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