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.
What Actually Goes Wrong in Form A Submissions
The recurring reasons SMF approval applications stall, and how to avoid them before you submit.
Read the analysis →The Certification Regime Explained: The “C” in SMCR
How certification works below Senior Manager level, and what firms must assess every year.
Read the analysis →Operational Resilience: Where Supervisory Expectations Stand
Important business services, impact tolerances and what it means for SMF24 holders.
Read the analysis →Consumer Duty and the SMF Framework
Where accountability for customer outcomes sits across the Senior Manager team.
Read the analysis →FCA Enforcement Trends: What SMF Holders Need to Know
What recent cases show about how the regulator judges “reasonable steps”.
Read the analysis →The Authorisation Journey: Building an SMF Team From Scratch
The Senior Managers a new firm needs to name, and when to recruit them.
Read the analysis →Interim and Fractional SMF Appointments
When part-time and interim Senior Managers work, and when they don’t.
Read the analysis →Diversity and Inclusion on Regulated Boards
Board composition and diversity of perspective at regulated firms.
Read the analysis →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.
Read the analysis →The Compliance Monitoring Plan
What the board should expect to see from its SMF16, and how weak plans show up in supervision.
Read the analysis →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.
- Consumer Duty and the SMF framework
- FCA enforcement trends
- Operational resilience expectations
- The Certification Regime explained
- Conduct Rules training guide
- The 12-week rule for temporary cover
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.
- What goes wrong in Form A submissions
- The authorisation journey
- How long an SMF appointment takes
- SMF timing and eligibility questions
- Going directly authorised
- Becoming an Enhanced firm
- Hiring your first Senior Manager
- Group SMF roles
- Preparing for an FCA or PRA approval interview
- SMF application refused or withdrawn: what happens next
- Adding an executive to the board: a checklist
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.
- Writing an SMF job description that works
- Internal promotion or external hire?
- Hiring from the FCA, the Big Four or industry
- Can a Senior Manager work remotely or from overseas?
- Offer subject to FCA approval: managing the gap
- Hiring a compliance officer: the experience that matters by firm type
- MLRO interview questions: testing financial crime judgement
- How many days a week does a fractional MLRO or compliance officer need?
- Fractional SMF agreements: what the contract should cover
- Accepting an SMF role: due diligence before you say yes
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.
- When to split a combined SMF16 and SMF17 role
- Interviewing a combined compliance officer and MLRO
- What a combined compliance officer and MLRO costs
- Compliance officer and MLRO for brokers and small advice firms
- Do you need a deputy MLRO?
- Head of financial crime or MLRO: same job or two?
- Hiring a sanctions lead
- Sizing the financial crime team at a payments or e-money firm
- Hiring a crypto MLRO
SMF Appointments in Practice
How Senior Manager searches actually run: checking candidates, structuring offers, covering departures and getting the designation right before you start.
- Pre-offer checks for SMF candidates
- Interviewing an SMF candidate
- Structuring an SMF offer
- SMF3 or SMF18?
- Combining Senior Manager roles
- Interim and fractional appointments
- Fractional or full-time compliance officer?
- Your MLRO has resigned: a 30-day plan
- The first 90 days for a new MLRO or compliance officer
- Senior Manager handovers: what a good handover pack contains
- The annual MLRO report: what the board should expect
- The compliance monitoring plan: what the board should see
- Staffing a section 166 remediation
- SMF succession planning
- Keeping the SMF team after an acquisition
- Writing a Statement of Responsibilities
- Who can be your MLRO or compliance officer?
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.
- Non-executive directors at FCA-regulated firms
- The Consumer Duty board champion
- The whistleblowers’ champion
- NED time commitment and overboarding
- PRA collective suitability
- The chair-CEO chemistry problem
- Diversity and inclusion on regulated boards
- Dual-regulated SMF hiring at banks and building societies
- SMF9: what the chair function requires
- SMF10 and SMF11: the risk and audit committee chairs
- SMF14: the senior independent director
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.
- The finance team behind your SMF16/17 holder
- Regulatory reporting: who supports your SMF16 and SMF17
- Financial controllers for FCA-regulated firms
- CASS accountants and client money experience
- Why an SMF2 search should start with a CFO recruiter
- Crypto and digital assets: the finance talent gap
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:
| Section | What it covers | Start here |
|---|---|---|
| Insights | Analysis of developments and how SMF appointments work in practice | You’re here |
| Knowledge Centre | Reference guides to the rules: fit and proper, references, notification forms, tiers, financial crime, templates | Knowledge Centre |
| SMF Designations | A guide to every Senior Manager Function, with links to each detailed guide | SMF designations guide |
| Templates | Free Word templates for Statements of Responsibilities, Responsibilities Maps, fit and proper assessments, references and board skills | Free guides and templates |
| Blog | All our articles in date order | Blog |
Free Templates
Several of our Insights link to free Word templates you can download and adapt:
- Statement of Responsibilities template
- Responsibilities Map template
- Fit and proper assessment template
- Regulatory reference checklist
- Board skills matrix template
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
Services
How we run SMF searches.
→ SMF recruitment services → Fractional and interim cover → Interim compliance and MLRO → Urgent SMF replacementAuthorisation support →
Control Functions
The roles we fill most often.
→ Compliance officer (SMF16) → MLRO (SMF17) → Fractional MLRO → Part-time compliance officerChief Risk Officer (SMF4) →
Executive & Board
Senior executive and board roles.
→ Regulated CEO (SMF1) → Chair and committee chairs → Executive director (SMF3) → Senior business heads (SMF18)COO (SMF24) →
Reference
The rules behind every appointment.
→ The fit and proper test → SMFs by firm tierTell us about your hire →
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.
Turning Insight Into an Appointment?
If one of these issues means you need a Senior Manager, tell us about your hire. We’ll come back to you the same working day.