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 led personally 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.
The Certification Regime Explained: The “C” in SMCR
How certification works below Senior Manager level, and what firms must assess every year.
Operational Resilience: Where Supervisory Expectations Stand
Important business services, impact tolerances and what it means for SMF24 holders.
Consumer Duty and the SMF Framework
Where accountability for customer outcomes sits across the Senior Manager team.
FCA Enforcement Trends: What SMF Holders Need to Know
What recent cases show about how the regulator judges “reasonable steps”.
The Authorisation Journey: Building an SMF Team From Scratch
The Senior Managers a new firm needs to name, and when to recruit them.
Interim and Fractional SMF Appointments
When part-time and interim Senior Managers work, and when they don’t.
Diversity and Inclusion on Regulated Boards
Board composition and diversity of perspective at regulated firms.
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
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
- 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
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 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, 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 | Template downloads |
| 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 led personally by Adrian Lawrence FCA
Services
How we run SMF searches.
→ SMF recruitment services
→ Fractional and interim cover
Control Functions
The roles we fill most often.
→ Compliance officer (SMF16)
→ MLRO (SMF17)
Executive & Board
Senior executive and board roles.
→ Regulated CEO (SMF1)
→ Chair and committee chairs
Reference
The rules behind every appointment.
→ The fit and proper test
→ SMFs by firm tier
Every SMF search is led personally 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 leads personally. 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.