Knowledge Centre: Guides, Q&As and Templates for the Senior Managers Regime
The SMF Capital Knowledge Centre is our reference library for the Senior Managers and Certification Regime. It explains the rules and mechanics behind every Senior Manager appointment, answers the practical questions firms ask before they hire, offers in-depth guides on topics from financial crime and client assets to prudential rules and enforcement, and provides free Word templates for the documents the regime requires. It’s written for the boards, compliance teams and candidates who have to apply the rules, and every SMF search we run is led personally by Adrian Lawrence FCA.
Start Here
New to the regime, or working out what applies to your firm? These three guides give you the framework.
- Senior Manager Functions explained: what the Senior Managers and Certification Regime is, why it exists and how it works.
- SMF designations: a complete guide: every Senior Manager Function from SMF1 to SMF29, with links to each detailed guide.
- Which SMFs apply at which firm tier?: the functions and responsibilities for Limited Scope, Core and Enhanced firms.
Core Reference Guides
The rules and processes behind every Senior Manager appointment.
The Fitness and Proper Test in Full
Every criterion behind the regulators’ three-part assessment, and how it’s applied.
Which SMFs Apply at Which Firm Tier?
A designation-by-designation map across Limited Scope, Core and Enhanced firms.
The Responsibilities Map Explained
What Enhanced firms must document, and how it fits with Statements of Responsibilities.
Regulatory References: The Six-Year Rule
What firms must request and give, and the information references must disclose.
The 12-Week Rule
How firms cover an unexpected Senior Manager vacancy after the April 2026 reforms.
Notification Forms B, C, D and E
The forms for withdrawals, leavers, changes and internal transfers, and their deadlines.
SMF Approval for Overseas Firms and Groups
How Senior Manager approval works for branches, subsidiaries and group structures.
Practical Q&As and New Guides
Direct answers to the questions firms ask most often when structuring and filling Senior Manager roles, plus guides for firms going through significant change.
Who Can Be Your MLRO or Compliance Officer?
Outsourcing, directors as MLRO, combined roles and fractional holders, answered for smaller firms.
Can One Person Hold More Than One SMF?
Which combinations usually work, which need safeguards and which the regulators question.
Can We Appoint Them Yet?
Starting before approval, notice periods, overseas candidates and past regulatory issues.
Non-Executive Directors at FCA-Regulated Firms
When a NED role needs approval, which Conduct Rules apply and what firms must check.
Conduct Rules Training: Complete Guide
All ten Conduct Rules, who they apply to, breach reporting and answers to common training questions.
Going Directly Authorised
The Senior Managers you’ll need when you leave an appointed representative network.
Becoming an Enhanced Firm
What changes when you cross the Enhanced threshold, and the SMF hires it brings.
SMF and Compliance Salary Guide
Salary and day-rate benchmarks for every main Senior Manager Function and compliance role.
In-Depth Regulatory Guides
Detailed guides to the rules, processes and roles that shape Senior Manager accountability, from financial crime and client assets to prudential requirements and enforcement.
What Is an MLRO?
The money laundering reporting officer explained: duties, legal liability, SMF17 and who can hold the role.
The Consumer Duty for Senior Managers
The four outcomes, fair value, vulnerable customers, board reports and Conduct Rule 6.
CASS Explained
Client money and custody rules, firm classification, CASS audits and who is accountable.
ICARA and IFPR Explained
Own funds, liquidity, harm assessment and wind-down planning for investment firm boards.
SMF7 Group Entity Senior Manager
When a group executive needs approval as a Senior Manager of the UK firm.
Prescribed Responsibilities Explained
Which Prescribed Responsibilities apply, how to allocate and share them, and common mistakes.
FCA Prohibition Orders
What prohibition orders are, when the FCA uses them and what they mean for careers.
Section 166 Skilled Person Reviews
Why the FCA orders a skilled person review, how it works and what it means for Senior Managers.
Payment and E-Money Institution Authorisation
The directors, MLRO, compliance and safeguarding people the FCA expects of APIs and EMIs.
Appointed Representatives Explained
How the AR regime works, principals’ responsibilities and when to go directly authorised.
The PRA and the FCA
Who regulates what, how dual regulation works and what it means for Senior Manager approvals.
Free Templates
Downloadable Word templates for the documents the regime requires. Each has a guide page explaining how to complete it, and each is free with no sign-up.
Statement of Responsibilities Template
Free Word template with section-by-section guidance and example wording for SMF16, SMF17 and SMF1.
Responsibilities Map Template
Free Word template for Enhanced firms: governance, Prescribed Responsibilities and overall responsibility.
Fit and Proper Assessment Template
Free Word template for annual assessments of Senior Managers and certified staff.
Regulatory Reference Checklist
Free Word checklist and tracker for requesting, chasing and giving references.
Board Skills Matrix Template
Free Word template rating board skills across 14 areas, with gap analysis and succession planning.
Guides by Topic
Getting a Senior Manager Approved
- The fitness and proper test in full
- What goes wrong in Form A submissions
- Regulatory references: the six-year rule
- How long an SMF appointment takes
- SMF timing and eligibility questions
- Hiring your first Senior Manager
- Pre-offer checks for SMF candidates
- Regulatory reference checklist
- PRA vs FCA: who approves what
Responsibilities and Structure
- The Responsibilities Map explained
- Responsibilities Map template
- Writing a Statement of Responsibilities
- Statement of Responsibilities template
- Combining Senior Manager roles
- SMF3 or SMF18?
- Group SMF roles
- SMF approval for overseas firms and groups
- Prescribed Responsibilities explained
- SMF7 Group Entity Senior Manager
Changes, Leavers and Notifications
- The 12-week rule
- Notification forms B, C, D and E
- Your MLRO has resigned: a 30-day plan
- SMF succession planning
- Keeping the SMF team after an acquisition
- Staffing a section 166 remediation
- Section 166 skilled person reviews explained
Conduct, Fitness and Certification
- Conduct Rules explained
- Conduct Rules training guide
- The Certification Regime explained
- Fit and proper assessment template
- FCA prohibition orders
Firm Status and Authorisation
- Which SMFs apply at which firm tier?
- Becoming an Enhanced firm
- Going directly authorised
- The authorisation journey
- Who can be your MLRO or compliance officer?
- Fractional or full-time compliance officer?
- Appointed representatives explained
- Payment and e-money institution authorisation
Financial Crime, Client Assets and Prudential Rules
- What is an MLRO?
- SMF16 and SMF17 explained
- CASS explained
- ICARA and IFPR explained
- The Consumer Duty for Senior Managers
- Consumer Duty and the SMF framework
Boards and Non-Executives
- Non-executive directors at FCA-regulated firms
- Board skills matrix template
- The Consumer Duty board champion
- The whistleblowers’ champion
- NED time commitment and overboarding
- PRA collective suitability
Designation Guides
Detailed guides to individual Senior Manager Functions:
- SMF1 Chief Executive
- SMF4 Chief Risk
- SMF5 Head of Internal Audit
- SMF9 Chair
- SMF10 and SMF11 Committee Chairs
- SMF12 Remuneration Committee Chair
- SMF14 Senior Independent Director
- SMF16 and SMF17
- SMF18 Other Overall Responsibility
- SMF24 Chief Operations
- SMF27 Partner
For the full list, including functions without a dedicated guide, see the SMF designations guide.
Knowledge Centre or Insights?
The Knowledge Centre explains the rules and how to comply with them. Our Insights section analyses developments, enforcement and how Senior Manager appointments work in practice. Many readers use both: the Knowledge Centre for what the rules require, and Insights for what that means when you have to appoint someone.
A Note on Sources
Our guides are written from experience of Senior Manager searches and refer to the regulators’ own rules, including the FCA Handbook and the PRA Rulebook. Rules change, so check the current requirements for your firm, and take legal or regulatory advice on specific situations. If you spot something that needs updating, please let us know.
From Reference to Recruitment
When the rules point to an appointment, 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
Advice Firms
Senior Managers and advisers.
→ RDR-qualified Senior Managers
→ Certified advisers
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Are the templates really free?
Yes. Download them from each template page, with no sign-up, and adapt them for use within your firm.
Is this legal or regulatory advice?
No. The Knowledge Centre provides general guidance. For advice on a specific situation, speak to your compliance team or a regulatory lawyer.
Where do I start if I need to appoint a Senior Manager?
Read which SMFs apply at your firm tier and SMF timing and eligibility, then tell us about your hire.
Where should I start as a new MLRO or compliance officer?
Read what an MLRO does, the SMF16 and SMF17 guide and the first 90 days.
Can you add a guide on a specific topic?
Yes. Get in touch and tell us what you need.
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 the Knowledge Centre guides, drawing on the Senior Manager searches he leads personally. View Adrian’s ICAEW profile.
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