What a Statement of Responsibilities Is

Under the Senior Managers and Certification Regime, every Senior Manager must have a Statement of Responsibilities. It records the Senior Manager Functions they perform, the Prescribed Responsibilities allocated to them and any other areas they’re responsible for. The FCA’s requirements are in SUP 10C of its Handbook.

It matters for three reasons. The regulator uses it to assess the approval application. It defines the scope of the individual’s accountability under the Duty of Responsibility. And at Enhanced firms, it must be consistent with the firm’s Responsibilities Map.

Important: Use the FCA’s Prescribed Form for Submission

The regulators prescribe the form in which Statements of Responsibilities are submitted. This template is a drafting and working template: use it to agree the content internally, then transfer it to the prescribed form when you submit the approval application or notify a significant change. Keeping the working version alongside your governance records also makes later updates much easier.

What’s in the Template

How to Complete Each Section

Senior Manager Functions

List every function the individual will perform. Each needs approval. If someone will hold two functions, such as SMF16 and SMF17, list both. Our page on combining Senior Manager roles explains which combinations work.

Prescribed Responsibilities

Use the regulators’ own wording for each Prescribed Responsibility, rather than paraphrasing. Which ones apply depends on the firm’s tier and permissions, so check which SMFs and responsibilities apply at your firm tier. Every Prescribed Responsibility that applies must be allocated to a Senior Manager.

Overall Responsibility

At Enhanced firms, every business area, activity and management function must have a Senior Manager with overall responsibility for it. List the areas this individual covers. This is where SMF18 often comes in for business heads without another function.

Other Responsibilities

This is where most statements go wrong. Be specific. “General oversight of compliance” tells the regulator very little. “Responsibility for the design and delivery of the risk-based compliance monitoring programme and quarterly reporting to the board” tells it exactly what the person owns.

Shared Responsibilities

Where a responsibility is shared, explain how. Vague sharing creates exactly the accountability gaps the regime was designed to remove.

Common Mistakes

• Vague wording that doesn’t say what the person actually owns.
• Paraphrasing Prescribed Responsibilities instead of using the rules’ wording.
• Inconsistency with the Responsibilities Map or with other Senior Managers’ statements.
• Responsibilities the person can’t realistically discharge in the time available.
• Not updating it when responsibilities change. Significant changes must be notified to the regulator.
• Not involving the individual. They should read, understand and agree it.

Our post on writing a Statement of Responsibilities that works covers these in more depth.

Example Wording

The template’s appendix includes example wording you can adapt:

Adapt every example to your firm’s structure, permissions and allocation of Prescribed Responsibilities. Example wording is a starting point, not a substitute for thinking about what your Senior Manager will actually do.

When to Update a Statement of Responsibilities

• when the individual takes on, gives up or shares a responsibility
• when the firm restructures or changes its business
• when the firm moves from Core to Enhanced. See becoming an Enhanced firm
• when another Senior Manager joins or leaves and responsibilities are reallocated
• at a regular review, at least annually

Firms must notify the regulator of significant changes. Our guide to the SMCR notification forms explains how.

For New Senior Managers

If you’re about to take on a Senior Manager role, ask to see your draft Statement of Responsibilities before you accept. It tells you exactly what you’ll be accountable for, and it’s much easier to clarify before you start than afterwards. Our guide for new compliance officers and MLROs covers what to do in your first months.

Using the Template in an Approval Application

A clear, specific Statement of Responsibilities strengthens an approval application, because it shows the regulator exactly what the candidate is being approved to do and lets it assess their competence against those responsibilities. Vague statements invite questions and delay. When we run a Senior Manager search, we start from the draft statement and build the role specification around it, so the candidate we introduce is matched to the responsibilities they’ll actually hold. Our guide to what goes wrong in Form A submissions covers the wider application.

Keeping Statements Consistent

At firms with several Senior Managers, read all the statements together. Responsibilities shouldn’t overlap without explanation, and nothing important should be left out. At Enhanced firms, the Responsibilities Map is the place to check this. Our Responsibilities Map template is designed to be used alongside this one, and our governance and SMF structure review can check the full set for gaps and overlaps.

Frequently Asked Questions

Is this the official FCA form?

No. It’s a drafting template. Transfer the agreed content to the regulators’ prescribed form for submission.

Who should prepare the Statement of Responsibilities?

Usually compliance or the company secretary, working with the individual and the chief executive or chair. The individual should agree the final version.

How long should it be?

As long as it needs to be to describe the responsibilities clearly. Specific is better than short.

Do certified staff need a Statement of Responsibilities?

No. Statements of Responsibilities are for Senior Managers.

Is the template free to use?

Yes. Download it, adapt it and use it within your firm. It’s general guidance, not legal or regulatory advice.