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Insights: Analysis of the Senior Managers Regime and SMF Hiring

SMF Capital’s Insights bring together our analysis of the Senior Managers and Certification Regime: what regulatory developments mean in practice, what enforcement tells us about personal accountability, and how Senior Manager appointments actually run. Everything here is written from direct experience of SMF searches, not as a restatement of the rulebook. Every search we run is overseen by Adrian Lawrence FCA.

Featured Analysis

Our core analysis pieces cover the issues firms and Senior Managers raise with us most often.

Authorisation

What Actually Goes Wrong in Form A Submissions

The recurring reasons SMF approval applications stall, and how to avoid them before you submit.

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Regime

The Certification Regime Explained: The “C” in SMCR

How certification works below Senior Manager level, and what firms must assess every year.

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Resilience

Operational Resilience: Where Supervisory Expectations Stand

Important business services, impact tolerances and what it means for SMF24 holders.

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Consumer Duty

Consumer Duty and the SMF Framework

Where accountability for customer outcomes sits across the Senior Manager team.

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Enforcement

FCA Enforcement Trends: What SMF Holders Need to Know

What recent cases show about how the regulator judges “reasonable steps”.

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Authorisation

The Authorisation Journey: Building an SMF Team From Scratch

The Senior Managers a new firm needs to name, and when to recruit them.

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Appointments

Interim and Fractional SMF Appointments

When part-time and interim Senior Managers work, and when they don’t.

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Boards

Diversity and Inclusion on Regulated Boards

Board composition and diversity of perspective at regulated firms.

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Financial Crime

The Annual MLRO Report: What the Board Should Expect

What a good MLRO report contains, how the board should challenge it, and what a weak one tells you.

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Compliance

The Compliance Monitoring Plan

What the board should expect to see from its SMF16, and how weak plans show up in supervision.

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Regulation and Accountability

The Senior Managers and Certification Regime keeps evolving, from the Consumer Duty to operational resilience to the 2026 reforms to how vacancies are covered. These pieces explain what the changes mean for the people who hold Senior Manager Functions and the firms that appoint them.

Authorisation and Approvals

Getting a Senior Manager approved is where many appointments slow down. These pieces cover the application, the timetable and the situations where firms need several approvals at once.

Hiring a Senior Manager

Before an SMF search starts, firms face a set of practical decisions: how to describe the role, whether to promote from within, which background suits the job, whether the role can be remote, how to interview for it, how much time a part-time appointment needs, and how to hold on to a candidate while the regulator decides. These pieces take each one in turn.

Compliance Officer, MLRO and Financial Crime Team

The questions firms ask most about their compliance and financial crime leadership: whether one person can be both compliance officer and MLRO, what that costs, when to split the role, and the team to build around the MLRO as the firm grows. Start with our page on combined compliance officer and MLRO recruitment and our financial crime leadership practice.

SMF Appointments in Practice

How Senior Manager searches actually run: checking candidates, structuring offers, covering departures and getting the designation right before you start.

The rulebook tells you what a Senior Manager is accountable for. Our Insights are about what that means when you have to appoint one.

Boards and Governance

Board-level Senior Managers carry personal accountability for how the board and its committees operate. These pieces cover the questions chairs, nomination committees and company secretaries raise with us.

The Finance Team Behind Senior Managers

A Senior Manager can only stand behind the numbers and assessments they’re accountable for if the team beneath them is right. These pieces cover the finance and reporting roles that support compliance officers, MLROs and finance leaders.

How to Use Our Insights

If You’re Hiring a Senior Manager

Start with the pieces on hiring a Senior Manager, approvals and appointments in practice. They’ll help you set a realistic timetable, check candidates properly and avoid the mistakes that delay approval. If you’re facing a specific situation, such as a resignation, a skilled person review, an acquisition or a move to Enhanced status, there’s a piece written for it above.

If You’re a Senior Manager or Candidate

The regulation and accountability pieces explain what the regulators expect of you personally, and the board pieces cover the questions non-executives face. If you’re preparing for your first Senior Manager role, read our guides to the fit and proper test and the first 90 days, and browse current roles on our jobs board.

If You Sit on a Board

The boards and governance pieces cover board-level Senior Manager Functions, collective suitability, time commitment and the champion roles regulators expect boards to fill. Our free board skills matrix template is a practical place to start.

What We’re Watching

The areas we expect to write about most over the coming months include further changes to the Senior Managers and Certification Regime, including the Certification Regime; how firms are evidencing Consumer Duty outcomes to their boards; operational resilience and third-party risk; the crypto-asset regime as firms move into full authorisation; and the effect of all of this on demand for compliance officers, MLROs and risk leaders. If there’s a development you’d like us to cover, let us know.

Pay and the Market

Pay for Senior Managers varies widely by designation, firm size, sector and location. Our SMF and compliance salary guide sets out current benchmarks and day rates, kept up to date as the market moves, and our earlier piece on what SMF roles actually pay looks at the drivers behind the numbers.

Insights, Knowledge Centre and Designation Guides

Our content is organised so you can find the right level of detail quickly:

SectionWhat it coversStart here
InsightsAnalysis of developments and how SMF appointments work in practiceYou’re here
Knowledge CentreReference guides to the rules: fit and proper, references, notification forms, tiers, financial crime, templatesKnowledge Centre
SMF DesignationsA guide to every Senior Manager Function, with links to each detailed guideSMF designations guide
TemplatesFree Word templates for Statements of Responsibilities, Responsibilities Maps, fit and proper assessments, references and board skillsFree guides and templates
BlogAll our articles in date orderBlog

Free Templates

Several of our Insights link to free Word templates you can download and adapt:

Podcast and Events

We also share what we learn through our podcast, SMF Unlocked, and free online briefings and candidate clinics. Visit the media centre for every podcast platform and press coverage, and the events page for upcoming dates.

From Insight to Appointment

When analysis turns into a hire, these are the services and roles we recruit for. Every SMF search is overseen by Adrian Lawrence FCA


Every SMF search is overseen by Adrian Lawrence FCA

Frequently Asked Questions

How often do you publish new Insights?

Regularly, usually weekly. New articles also appear on our blog.

Is this regulatory or legal advice?

No. Our Insights are general analysis based on our recruitment experience. For advice on a specific situation, speak to your compliance team or a regulatory lawyer.

Can you write about a specific topic?

Yes. If there’s an SMF or SMCR question you’d like covered, get in touch.

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. He writes and reviews SMF Capital’s Insights, drawing on the Senior Manager searches he oversees. View Adrian’s ICAEW profile.

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