SMCR Training: What Firms Must Provide and Who Needs It
Every firm within the Senior Managers and Certification Regime has to train its people on the rules that apply to them. Training isn’t just good practice here: the FCA’s Code of Conduct requires firms to tell staff which Conduct Rules apply to them and take reasonable steps to make sure they understand what that means in their own role. This guide covers who needs SMCR training, what it should cover for each group, how to evidence it, and how to choose between an external course and training delivered in-house.
The Training Requirement
The SMCR training requirement sits in the FCA’s Code of Conduct sourcebook, COCON. Firms must notify every person the Conduct Rules apply to, and take all reasonable steps to ensure they understand how the rules apply to them. In practice that means training, and training that is relevant to the person’s actual role rather than a generic presentation of the rules.
There is no prescribed course, syllabus or number of hours. The FCA’s approach is outcome-based: it expects firms to be able to show that their people understand the standards they are held to. The FCA’s SMCR pages set out the wider expectations, and dual-regulated firms should also consider the PRA’s requirements for their Senior Managers.
This guide focuses on how firms structure SMCR training as a whole. For detailed answers on the Conduct Rules themselves, including breach reporting and common training questions, see our Conduct Rules training guide.
Who Needs SMCR Training
Almost everyone in a regulated firm needs some SMCR training, but the content and depth should differ by group.
| Group | Rules that apply | What their training should focus on |
|---|---|---|
| Senior Managers | Individual Conduct Rules plus the Senior Manager Conduct Rules | Personal accountability, the Duty of Responsibility, reasonable steps, their Statement of Responsibilities, delegation and oversight, handovers |
| Certified staff | Individual Conduct Rules | The Conduct Rules in the context of their certified function, annual fit and proper certification, breach reporting |
| Other conduct rules staff | Individual Conduct Rules | What the five Individual Conduct Rules mean in practice, with examples from their own work |
| Non-executive directors | The Conduct Rules relevant to their role; some NEDs hold Senior Manager Functions | Board-level accountability, challenge and oversight, and for chairs and committee chairs, their Senior Manager responsibilities |
A small number of ancillary staff, such as some receptionists, security and catering staff, are outside the Conduct Rules. Firms should confirm which of their people fall in or out of scope, and keep that list current as roles change. Our guide to who the Conduct Rules apply to covers the scope in more detail, and our guide to the Certification Regime explains who counts as certified staff.
What Good SMCR Training Covers
The best SMCR training starts with the rules but quickly moves to what they mean for the person in the room. Core topics:
- The Individual Conduct Rules, with practical examples for each role, from acting with integrity to Rule 6 on acting to deliver good outcomes for retail customers
- The Senior Manager Conduct Rules, for those who hold Senior Manager Functions
- The Duty of Responsibility and what “reasonable steps” means in practice
- Statements of Responsibilities and, at Enhanced firms, the Responsibilities Map
- Delegation and oversight, and the records a Senior Manager should keep
- Handovers when a Senior Manager joins or leaves
- Breach identification and reporting, including what happens internally when a possible breach is raised
- The Consumer Duty and how it connects to Conduct Rule 6
- Fitness and propriety, regulatory references and annual certification
- Speaking up and the firm’s whistleblowing arrangements
Our guides to the Duty of Responsibility and the Consumer Duty for Senior Managers are useful background for anyone designing training on these areas.
Training Senior Managers
Senior Manager training should be personal. A Senior Manager needs to understand not just the rules, but what they mean for the specific responsibilities in their own Statement of Responsibilities. Generic training on the regime rarely achieves that. The most effective programmes include:
- A walk-through of the Statement of Responsibilities, covering each responsibility, the risks attached to it and the evidence the person would need to show they took reasonable steps.
- Scenario discussions based on realistic situations in the person’s own area, such as a delegated task going wrong or a control failing.
- A review of management information, so the Senior Manager knows what they should be seeing and when to escalate.
- A clear explanation of record-keeping, so decisions, challenges and escalations are documented as they happen.
New Senior Managers benefit from this soon after approval, as part of their induction. Our guide to the first 90 days for a new MLRO or compliance officer shows how training fits into a broader onboarding plan.
Induction and Refresher Training
Training should happen at two points. Induction training covers new joiners before or soon after they start in a role covered by the Conduct Rules, and new Senior Managers when they take up their function. Refresher training keeps the rules current and reflects changes to the regime, the firm and the person’s role.
The rules don’t specify a refresher frequency. Most firms run refresher training annually, often alongside the annual fit and proper assessment, and add targeted sessions when the rules change, such as when the Consumer Duty was introduced. A change of role should also trigger fresh training, particularly when someone becomes a Senior Manager or takes on a certified function.
Evidencing Training
Training that can’t be evidenced is hard to rely on if the FCA asks how the firm met its obligations. Good records include:
- who was trained, when, and on which content;
- attestations that the person has read and understood the Conduct Rules that apply to them;
- assessment results where the firm uses testing to check understanding;
- attendance at role-specific sessions for Senior Managers and certified staff; and
- follow-up for anyone who missed training or failed an assessment.
Training records also feed into the annual fit and proper assessment of Senior Managers and certified staff. Competence and capability is one of the three fit and proper criteria, and evidence of up-to-date regulatory training supports the assessment. Our fit and proper assessment template includes a section for it.
External Course or In-House Training?
| Option | Strengths | Watch for |
|---|---|---|
| External SMCR training course | Expert delivery, up-to-date content, useful for small firms without a compliance training function | Generic content that doesn’t reflect the firm’s own roles, products and risks |
| E-learning platform | Scalable, automatic records and attestations, easy to schedule refreshers | Can become a box-ticking exercise without role-specific discussion |
| In-house training led by compliance | Tailored to the firm’s own activities, examples and Statements of Responsibilities | Depends on the compliance team’s time and training skills |
| Combined approach | E-learning for all staff, with in-house sessions for Senior Managers and certified staff | Needs coordination so content stays consistent |
Many firms use a combined approach: an e-learning module or external course for the baseline, and in-house sessions led by the compliance officer for Senior Managers and certified staff. Whatever the mix, the compliance officer usually owns the programme and reports on it to the board.
Scenario: A wealth manager rolls out an off-the-shelf SMCR e-learning course to all staff each year and records completion rates of almost 100 per cent. When a complaint reveals that an adviser didn’t recognise a vulnerable customer, an internal review asks how the firm had trained staff on Conduct Rule 6 and the Consumer Duty. The e-learning covered the rule in a single slide. The firm keeps the e-learning for the baseline but adds short, role-specific sessions run by its compliance officer, using real anonymised cases from its own client files, and starts testing understanding rather than simply recording completion.
Common Failings
- one-size-fits-all training that doesn’t distinguish Senior Managers from other staff
- completion records without any evidence of understanding
- no training for non-executive directors, or training that ignores their Senior Manager roles
- Senior Managers never walked through their own Statements of Responsibilities
- refresher training that never changes from year to year
- staff in scope of the Conduct Rules missed because the in-scope list is out of date
- no link between training records and the annual fit and proper assessment
Training and Recruitment
SMF Capital is a recruitment practice, not a training provider. But training and hiring are closely connected. When we recruit a Senior Manager, we look for evidence that they understand their personal accountability under the regime, and we often see training gaps that a new appointment exposes. A strong compliance officer will usually own the firm’s SMCR training programme, so the quality of that hire shapes the quality of training across the firm. Our pages on compliance officer recruitment and combined compliance officer and MLRO recruitment cover those roles.
We also share what we see in the market through free online events and webinars and the SMF Unlocked podcast; see media, podcast and events. For definitions of the terms used in this guide, see our SMCR glossary.
SMCR Guidance and Recruitment
The rules, the roles and the people. Every SMF search is led personally by Adrian Lawrence FCA
Conduct Rules
The standards behind the training.
→ Conduct Rules training guide → Conduct Rules explainedThe Certification Regime →
Accountability
What Senior Managers answer for.
→ Duty of Responsibility → Statements of ResponsibilitiesSMCR explained →
Compliance Leaders
The people who own the programme.
→ Compliance officer (SMF16) → Part-time compliance officerCombined compliance officer and MLRO →
Templates
Free tools for the regime.
→ Fit and proper assessment → Statement of ResponsibilitiesAll free guides →
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Is SMCR training mandatory?
Firms must notify staff of the Conduct Rules that apply to them and take reasonable steps to ensure they understand them. In practice that means training, although the FCA doesn’t prescribe a specific course.
How often should SMCR training happen?
The rules don’t set a frequency. Most firms train on induction, refresh annually and add targeted training when rules or roles change.
Do non-executive directors need SMCR training?
Yes. NEDs are subject to Conduct Rules relevant to their role, and those holding Senior Manager Functions such as chair or committee chair need training on their personal accountability.
Is there an accredited SMCR qualification?
There is no single required qualification. Many providers offer SMCR courses; firms should choose content that reflects their own roles and risks.
Does SMF Capital provide SMCR training?
No. We recruit Senior Managers and compliance leaders, and share guidance through our Knowledge Centre, events and podcast.
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 leads every SMF Capital search personally. View Adrian’s ICAEW profile.
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