Can One Person Hold SMF16 at More Than One Firm?
Yes. There is no rule that stops an experienced compliance officer holding SMF16 at two, three or four unrelated firms at once, and most fractional compliance officers do exactly that. But each appointment is approved separately, each firm has to be satisfied the person has enough time, and the regulator will look at the whole portfolio when it reviews the application. This guide explains the real limits, what the FCA looks at and how firms and candidates should handle multiple appointments.
The Short Answer
The FCA does not set a maximum number of firms at which one person can hold the SMF16 Compliance Oversight function, or the SMF17 MLRO function. What it does require is that every Senior Manager is fit and proper for each role, including having the time and capacity to do it properly. The same applies to an individual holding both functions, which is common at smaller firms.
So the limit is practical rather than numerical. One experienced compliance officer can serve several small, low-risk firms well. The same person serving several fast-growing retail firms may not be able to give any of them what they need. If you want the background on the function itself, see our guide what is SMF16?
Multiple Firms vs Multiple Functions
Two different questions are often confused:
- Holding several functions at one firm, such as SMF16 and SMF17 together, or compliance and risk. That is covered in our guide to whether one person can hold more than one SMF, including holding the same function across companies in one group.
- Holding the same function at several unrelated firms, which is how the fractional model works. That is the subject of this guide.
The regulatory approach is similar in both cases: the question is always whether the person can do every role they hold properly, with the time, independence and support each needs.
What the FCA Looks At
Each firm that wants to appoint the individual submits its own Form A, and the FCA assesses them against the fit and proper test for that role. Where a candidate already holds other roles, it will want to understand:
- Time commitment. How many days the role at this firm needs, and how many the candidate has committed elsewhere.
- The nature of the other firms. Their size, risk and sector. Four small wholesale firms are very different from four high-volume payments firms.
- Conflicts of interest. Whether any of the firms compete, share clients or have dealings with each other.
- Availability for urgent matters. How the candidate would deal with incidents at two firms at once, and, for an MLRO, how suspicious activity reports are handled on days they are not working.
- Support. Whether each firm gives the holder the staff, systems and access they need.
The FCA can and sometimes does question applications where a candidate’s commitments look stretched. Applications that set out the time commitment clearly, with a realistic sizing of each role, avoid most of these questions. Our guide to what goes wrong in Form A submissions covers the wider application.
How Many Firms Is Realistic?
From the fractional appointments we see, most experienced fractional compliance officers and MLROs hold between two and four roles at once. Where they sit in that range depends on the days each firm needs:
| Typical portfolio | Days per firm | Comment |
|---|---|---|
| Two firms | Two days a week each | Growing firms with retail customers or client money |
| Three firms | One to one and a half days a week each | Small brokers, advisers and wholesale firms |
| Four firms | Two to four days a month each | Very small, stable, lower-risk firms |
Portfolios much larger than this are where questions start, from the FCA and from boards. A holder also needs slack in the week: board meetings cluster, incidents happen, and the first three months at any new firm take more time than the steady state. Our guide to how many days a fractional compliance officer needs explains how to size each role.
Scenario: An experienced compliance officer holds SMF16 and SMF17 at two small IFAs, one day a week each, and SMF16 at a corporate finance boutique for two days a month. A consumer credit broker asks her to take on SMF16 for two days a week. Before accepting, she reviews the time each firm really needs, finds the boutique has grown, and agrees an extra day there. She declines the broker, because the total would leave no room for urgent work, and the broker’s board appreciates being told why.
What Each Firm Must Do
Every firm that appoints a fractional SMF16 carries the same obligations as if it had employed them full-time. Each firm must:
- Run its own checks. Including regulatory references covering the previous six years and a criminal records check. Since the April 2026 changes, criminal records checks for Senior Manager candidates remain valid for six months. See regulatory references and pre-offer checks.
- Agree a statement of responsibilities specific to the firm, which sets out what the holder is accountable for there. Our statement of responsibilities template includes an example for a combined SMF16 and SMF17.
- Record the time commitment in the contract, with arrangements for urgent matters and absence. See fractional SMF agreements.
- Ask about other roles and conflicts, and require the holder to tell the firm before taking on new ones.
- Keep assessing fitness and propriety on an ongoing basis, including whether the time commitment still works as the firm and the holder’s portfolio change. Our fit and proper assessment template helps.
What It Means for the Individual
A fractional SMF16 is accountable at every firm, not just the busiest one. The Senior Manager Conduct Rules and the duty of responsibility apply separately to each appointment. If something goes wrong at one firm, the regulator will ask whether the holder took reasonable steps there, and “I was busy at another client” is not a defence. That makes three habits essential:
- keeping a clear record, at each firm, of what was reviewed, escalated and reported;
- telling a firm early when its needs have outgrown the days agreed; and
- turning down new appointments when the portfolio is full.
Each appointment also appears on the FCA Register, so boards and regulators can see the whole portfolio. Our guide to checking an SMF holder on the FCA Register shows how.
Larger Firms and Board Roles
The fractional model is designed for smaller firms. At larger firms, and particularly where the compliance leader is also a director, the role normally needs a full-time holder. If a candidate also holds board directorships at large banks or insurers, the PRA’s limits on the number of directorships members of the management body may hold can apply. If your firm is approaching the Enhanced tier of the SMCR, see becoming an Enhanced firm.
How We Handle This in a Search
When we put forward fractional SMF16 and SMF17 candidates, we check their current appointments, the days each takes and any conflicts before they reach you, and we tell you plainly if we think a portfolio is too full. Our fractional compliance officer (SMF16) and fractional MLRO (SMF17) pages explain how we run those searches.
Related Services and Guides
Fractional Senior Managers, approved for your firm. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate
Fractional SMF16
Compliance officers, part of the week.
→ Fractional compliance officer → Compliance officer and MLRO for small firmsFractional or full-time? →
Fractional SMF17
MLROs, part of the week.
→ Fractional MLRO → Combined SMF16/17What it costs →
Contracting
Time, terms and cover.
→ Fractional SMF agreements → How many days a weekFractional and interim SMF cover →
Approval
Checks and the Form A.
→ Pre-offer checks → Fit and proper templateForm A pitfalls →
Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate
Frequently Asked Questions
Is there a limit on how many firms an SMF16 can work for?
There is no numerical limit. Each firm and the FCA must be satisfied that the person has the time and capacity to do each role properly.
Does each firm need its own FCA approval?
Yes. Each firm submits its own Form A, and the individual is approved separately for each.
Can the same person be SMF16 and SMF17 at several firms?
Yes, and many fractional holders do. Each firm needs a cover arrangement for nominated officer duties on days the holder is not working.
Do we need to know about the holder’s other clients?
You should know how many other appointments they hold, the days each takes and any conflicts. The other firms’ names are usually on the FCA Register anyway.
What happens if our fractional SMF16 takes on too much?
Raise it with them and, if needed, the board. If they cannot give the role the time it needs, agree more days or plan a replacement, using interim cover if necessary.
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 oversees every SMF Capital search. View Adrian’s ICAEW profile.
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Adrian Lawrence FCA is the founder of SMF Capital and a Fellow of the Institute of Chartered Accountants in England and Wales and holds an ICAEW practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience working with boards, investors and business owners across the UK. He founded SMF Capital to help FCA and PRA-regulated firms appoint the Senior Managers the regulators expect, with the fit and proper assessment built into every search, and oversees every Senior Manager Function search.