How to Check Who Holds an SMF on the FCA Register
The Financial Services Register is the quickest way to see who a firm’s Senior Managers are, when they were approved and what else they have done in regulated financial services. Boards use it before an appointment, HR teams use it to confirm a candidate’s story, compliance teams use it to check their own firm’s records, and candidates use it to research a firm before they accept a role. This guide shows how to search it properly, what it can and cannot tell you, and where it fits in a sensible pre-offer process.
What the Register Is
The FCA describes the Financial Services Register as a public record of firms, individuals and other bodies that are, or have been, authorised by the FCA or the PRA. It covers solo-regulated firms and dual-regulated banks, building societies and insurers in one place, so there is no separate public register of individuals to check on the PRA side. It also lists appointed representatives and carries warnings about unauthorised and clone firms.
For individuals, the Register holds two broad groups. People approved by the regulator to perform a Senior Manager Function show a status of “Approved by regulator”. People whose fitness the firm itself assesses, such as certified staff, show as “Certified / assessed by firm”. The second group is what the FCA calls the Directory, which is published on the Register rather than as a separate website. If you need a refresher on which roles are which, see Senior Manager Functions explained and the Certification Regime explained.
Step by Step: Checking a Firm’s Senior Managers
- Go to the Register. Open register.fca.org.uk and choose to search for a firm.
- Search by name or Firm Reference Number. The FRN is the most reliable route, because several firms in a group can share similar names. You will usually find the FRN in the footer of the firm’s website or on its letters.
- Confirm you have the right entity. Check the registered address, status and permissions. Groups often contain several regulated companies, and the Senior Managers may differ between them.
- Open the individuals section. The firm page lists the people associated with it. Look for those shown as approved by the regulator, which is where Senior Manager Functions appear.
- Read the function and dates. Each role shows the function, for example SMF16 Compliance Oversight, and an effective date. Previous holders appear with an end date.
- Open the individual’s own record. Clicking a name takes you to their page, identified by an Individual Reference Number (IRN). This shows current roles and activities across all firms, previous roles and any disciplinary history.
- Check for restrictions. Look for suspensions, restrictions or conditions recorded against a role, and for any enforcement history.
- Record what you found. Save the date of your search and a screenshot or note of the entries. The Register changes, and you may need to show later what it said at the time.
Searching for an individual directly
You can also search for a person by name or IRN. Name searches can return several people with the same name, so use middle names, the firms they say they worked for and the dates to make sure you are looking at the right record. If a candidate has changed their name, the Directory records previous names, which helps join up the history.
What the Register Shows and What It Does Not
| What the Register shows | What it does not show |
|---|---|
| Senior Manager Functions currently held, with the firm and effective date | Applications still being considered by the regulator |
| Previous roles, with start and end dates | Why someone left a role or what the firm reported on Form C |
| Certified staff, non-SMF directors and qualified customer-facing staff, through the Directory | Staff who are neither SMFs nor directory persons |
| Roles at both solo-regulated and dual-regulated firms | Internal disciplinary findings or performance concerns |
| Disciplinary history and public enforcement action | Matters still under investigation that have not been made public |
| Restrictions or suspensions recorded against a role | The content of statements of responsibilities |
| Previous names for directory persons | Qualifications, other than memberships shown for some customer-facing roles |
Non-executive directors
Non-executive directors who chair the board or a committee, or act as senior independent director, usually hold an SMF and appear as approved. Other non-executive directors are not Senior Managers, but the FCA’s Directory includes directors who do not perform Senior Manager Functions, so they should appear with the firm-assessed status. If a NED you expected to see is missing, ask the firm. Our page on non-executive directors at FCA-regulated firms sets out which NED roles need approval.
Pending applications
An SMF application under review does not show the person as holding the function. Approval appears once it is granted and processed. For a candidate who has accepted an offer subject to approval, the Register will show only their existing and past roles until then. See offer subject to FCA approval for how to manage that period.
Time lags and accuracy
The Register is only as current as the information firms submit and the regulator processes. Firms must tell the regulator when a Senior Manager stops performing a function, and the FCA’s rules for directory persons require changes to be submitted within seven business days, with an annual attestation that the data is accurate. Data that has not been attested can be marked as out of date. Even so, there will be gaps: a Senior Manager may have left last week and still appear as current. Treat the Register as strong evidence, not as proof on its own. The FCA’s directory persons page explains what firms must keep up to date.
Checking History, Prohibitions and Enforcement
An individual’s record shows disciplinary history where the regulator has taken public action. Prohibition orders and other final notices are also published on the FCA’s website, and the Register records where an individual is prohibited. Our guide to FCA prohibition orders covers what a prohibition means for a firm considering an appointment.
A clean record is not the same as a clean history. The Register will not show issues a former employer dealt with internally, conduct rule breaches that did not lead to public action, or concerns that only appear in a regulatory reference. That is why the Register is one check among several, not the whole process.
Practical Uses
Pre-offer checks on a candidate
Before you offer an SMF role, compare the candidate’s CV with their Register record. The roles, firms and dates should line up. Gaps or inconsistencies are not automatically a problem, since people work in unregulated roles or for firms abroad, but they should be explained before an offer goes out. Our posts on pre-offer checks for SMF candidates and SMCR background checks cover the full set of checks that should sit alongside the Register search.
Regulatory references
The Register tells you which regulated firms a candidate has worked for and when, which helps you identify every firm you need a regulatory reference from over the relevant period. It does not replace the reference itself. See regulatory references and the six-year rule.
Researching a competitor or acquisition target
The Register is a quick way to see a firm’s senior line-up: who holds the compliance oversight and MLRO functions, whether one person holds several roles, how long people have been in post and whether there has been recent turnover. For a buyer, that is useful context before due diligence starts. Our post on keeping the SMF team through an acquisition covers what to do with what you find.
Checking your own firm
Compliance teams should check the firm’s own entry after every Senior Manager change and at least annually. Look for leavers still shown as current, roles missing after a new approval, wrong effective dates, and directory persons who are missing or out of date. If something is wrong, the fix is usually the relevant notification form, such as Form C when someone stops performing a function or Form E when they move between functions. Our guide to SMCR notification forms B, C, D and E explains which form applies.
Candidates researching a firm
If you are considering an SMF role, the Register shows who you would be working alongside, how long your predecessor held the role and how often it has changed hands. Frequent turnover in the same function is worth asking about at interview. See due diligence before accepting an SMF role.
Scenario: A board is close to offering its compliance oversight role to a candidate whose CV lists six years as SMF16 at a previous firm. The Register shows the candidate approved as SMF16 for only the last two of those years, having been certified staff before that. The difference is innocent: the candidate ran the function as deputy before being approved. Because the board checked before the offer, it could ask the question early, adjust the reference requests and avoid an awkward conversation later.
The PRA Side for Dual-Regulated Firms
At banks, building societies, PRA-designated investment firms and insurers, many Senior Manager Functions are approved by the PRA with the FCA’s consent. Those approvals still appear on the same Financial Services Register. The PRA’s own material on accountability, including the Senior Managers Regime as it applies to dual-regulated firms, is on the Bank of England’s strengthening accountability page. For how the two regulators split responsibility, see PRA versus FCA dual regulation for Senior Managers.
Common Mistakes When Using the Register
- Checking the wrong entity in a group with several regulated companies.
- Relying on a name match without checking the IRN, firms and dates.
- Treating a clean record as a full background check and skipping references.
- Not recording the search, leaving no evidence of what was checked and when.
- Ignoring your own firm’s entry until a client, auditor or buyer points out an error.
- Reading too much into a gap, when the person was in an unregulated or overseas role.
How This Fits Into Our Pre-Offer Checks
When we present an SMF candidate, we check their Register record against their CV before the shortlist goes to the client, and flag anything that needs explaining. That is the start of the process, not the end. Clients still need regulatory references, criminal record and credit checks where appropriate, and their own fit and proper assessment. Our regulatory reference checklist helps make sure nothing is missed.
The Bottom Line
The Register is free, public and quick to use, and every board, HR team and compliance function should know how to read it. It tells you who holds which function and since when, and whether the regulator has taken public action. It does not tell you why people left, what their references say or whether your own firm’s data is right unless you check. Use it early, record what you find and treat it as one part of a wider set of checks.
SMF Checks and Appointments
Getting the right Senior Manager approved. Every SMF Capital search is overseen by Adrian Lawrence FCA
Pre-Offer Checks
Checks before an SMF offer.
→ Pre-offer checks → SMCR background checksRegulatory references →
Notifications
Keeping records accurate.
→ Forms B, C, D and E → Form A pitfallsSMF authorisation support →
Senior Managers
Search for approved roles.
→ SMF recruitment services → Retained executive searchSMF designations guide →
Fitness and Propriety
Assessing the candidate.
→ Fit and proper template → Reference checklistThe fit and proper test →
Every SMF Capital search is overseen by Adrian Lawrence FCA
Frequently Asked Questions
Does the FCA Register show Senior Managers at dual-regulated firms?
Yes. The Register covers firms and individuals authorised by either the FCA or the PRA, including PRA-approved Senior Managers.
Are certified staff on the Register?
Yes. Certified staff appear through the FCA Directory, which is published on the Register, with the status “Certified / assessed by firm”.
Will an SMF application show while it is pending?
No. The function appears once approval has been granted and processed.
Can I rely on the Register instead of references?
No. It shows roles, dates and public action, but not reasons for leaving or internal concerns. Regulatory references are still required.
Our Register entry is wrong. What should we do?
Identify the cause and submit the right notification, often Form C for a leaver or Form E for a move between functions, or update the directory persons data within seven business days of a change.
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.
Hiring a Senior Manager?
Tell us about the role and the firm. We will check candidates against the Register before they reach you and help you plan the rest of the pre-offer process.
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 personally leads every Senior Manager Function search.