What Actually Goes Wrong in Form A Submissions
Some Form A applications clear without a single follow-up question. Others drag on for months. The difference is rarely the candidate. It is whether the firm has shown that it tested the candidate, or has simply asserted that they are fit and proper and hoped the paperwork would carry it. We see the same causes of delay across firms and designations. This guide sets out what they are, what the 2026 reforms changed and how to avoid them.
How the Process Works
Form A is the application to approve a person to perform a Senior Manager Function. The firm submits it through FCA Connect, with a Statement of Responsibilities and, where relevant, an updated responsibilities map. For dual-regulated firms, the PRA leads on its own functions and the FCA consents. The regulator has a statutory period to decide: three months from receiving a complete application, under section 61 of FSMA. If the application is incomplete, the clock effectively restarts when the missing information arrives, so the practical timetable depends on getting it right first time.
The regulator assesses the candidate against the fit and proper test: honesty, integrity and reputation; competence and capability; and financial soundness. Everything in the application should be evidence for one of those three.
What Changed in 2026
The first phase of the SMCR reforms took effect on 24 April 2026. For Form A, the main changes are:
| Change | Effect on applications |
|---|---|
| Criminal record checks valid for longer (six months) | Less risk of a check expiring while the application is prepared; Form A systems recognised the new period from 10 July 2026 |
| Regulatory references due within four weeks | Previous employers must respond faster, so references should no longer be the bottleneck |
| Group criminal record check exemption (PRA) | An existing SMF holder moving within a group can avoid a new check if the gap is no more than a month |
| 12-week rule reframed | Firms must submit the application within 12 weeks of an unexpected vacancy, rather than obtain approval within it |
None of this changes what the regulator is looking for. Faster processes help only if the application is complete. Our guide to the SMCR reforms covers the wider programme.
1. The Assessment Came After the Hiring Decision
This is the most common root cause of a difficult application. A firm chooses its candidate, makes an offer, and only then starts collecting the fit and proper evidence. By then it has every reason to present the evidence favourably, and the submission reads as advocacy rather than assessment. That invites questions.
Applications built from an assessment done during the search, before the decision, read differently. They show a firm that tested the candidate, including on their weaknesses, rather than one justifying a choice already made. Our guide to pre-offer checks explains what to do before the offer.
2. Gaps or Ambiguity in Employment History
Unexplained gaps, vague job descriptions or differences between the CV and what references confirm are among the most common triggers for follow-up. Gaps themselves are normal: career breaks, redundancies and sabbaticals happen. What matters is that every gap has a clear explanation the firm has verified, not one it accepted at face value. The application asks for a full history; give one, with dates that match the references.
3. Regulatory References That Tell a Different Story
Firms must request regulatory references covering the past six years from previous regulated employers, under SYSC 22. Those employers must disclose relevant conduct breaches and disciplinary action. An application that presents a clean picture while a reference reveals something else is one of the fastest ways to stall. Request references early, ideally before the offer is final, so any discrepancy surfaces while there’s time to understand it. Our regulatory reference checklist helps.
4. A Generic Statement of Responsibilities
A vague or templated Statement of Responsibilities tells the regulator the firm hasn’t thought about what this person will be accountable for. A strong one is specific to the firm, names real accountabilities, matches the Prescribed Responsibilities allocated to the role, and doesn’t overlap with or leave gaps between other Senior Managers. Firms that draft it at the last minute generate more questions. See writing a Statement of Responsibilities that works and our template.
5. Prior Regulatory History Glossed Over
A previous supervisory finding, a complaint, a role at a firm that later had problems: any of these needs addressing directly. The regulator can see a candidate’s regulatory history whatever the firm discloses. An application that appears to minimise a known issue reads far worse than one that explains it honestly, along with what the candidate learned or changed. Where something material is involved, bring in specialist regulatory counsel before submission, not after a query arrives.
6. Competence Asserted, Not Shown
“The candidate has extensive experience in this area” is an assertion. Specific examples are evidence: named roles with dates and reporting lines a reference can confirm, particular regulatory projects, measurable outcomes. This is the difference between a search that tested for the SMF’s specific accountabilities and one that assessed general seniority and translated it into fit and proper language afterwards. Where a candidate is stepping up, say so and explain the support in place, such as training, a handover or a mentor.
7. Time Commitment Not Explained
For non-executive, part-time and fractional appointments, the regulator will ask whether the person has the time. Applications should state the expected days, list the candidate’s other roles and explain how conflicts are managed. This matters for fractional SMF arrangements and for NEDs with several boards; see NED time commitment.
8. Inconsistencies Across the Documents
The Form A, the Statement of Responsibilities, the responsibilities map, the CV and the references should tell the same story. Different job titles, reporting lines that don’t match the map, or responsibilities claimed by two people all prompt questions. One person should read the whole pack before it goes in.
Scenario: A consumer credit firm submits a Form A for a new compliance officer. Six weeks later the FCA asks about an 11-month gap in her history and a reference describing her previous role as “compliance analyst” rather than “head of compliance”. Both have simple explanations: a sabbatical and an internal title change. But neither was in the application. The firm answers, and approval follows two months later than planned. On its next hire, the firm uses our process: history verified and references requested before the offer, with explanations written into the application. That one clears without questions.
The Practical Fix
Every one of these problems comes from treating fit and proper as a final compliance step rather than the organising principle of the search. In our searches we build the evidence as we go: employment history verified at shortlist stage, references requested early, competence tested against the specific SMF, and the Statement of Responsibilities drafted alongside the offer. That is why we treat the application as part of the search rather than an afterthought. If an application has already been refused or withdrawn, our guide to what happens next explains the options, and our SMF authorisation support service can help prepare a stronger one.
While an application is pending, the candidate can’t perform the function. Our guide to managing the gap between offer and approval covers how to plan around it.
SMF Approval Support
Applications that clear first time. Every SMF search is overseen by Adrian Lawrence FCA
Approval
Preparing strong applications.
→ SMF authorisation support → Retained executive searchApproval interviews →
Key SMF Hires
The roles we fill most.
→ Combined SMF16/17 → Regulated CEO (SMF1)Senior Manager Functions →
Templates
Documents for the application.
→ Statement of Responsibilities → Fit and proper templateRegulatory reference checklist →
Timing
Planning the timetable.
→ Fractional and interim SMF cover → Urgent SMF replacementHow long SMF appointments take →
Every SMF search is overseen by Adrian Lawrence FCA
Frequently Asked Questions
How long does the FCA take to decide a Form A?
The statutory deadline is three months from receiving a complete application. Incomplete applications take longer because the clock depends on the missing information arriving.
What is the most common reason for delay?
Incomplete or inconsistent information, usually unexplained gaps in employment history, references that don’t match the CV, or a generic Statement of Responsibilities.
When should we request regulatory references?
As early as possible, ideally before the offer is final. Since April 2026 previous employers must respond within four weeks.
Can the candidate start before approval?
Not in the SMF itself. Under the 12-week rule a firm can cover an unexpected vacancy temporarily, but the application must be submitted within 12 weeks.
Will the candidate be interviewed?
Sometimes. Interviews are more common for senior roles, dual-regulated firms and candidates without UK SMF experience.
What if the application is refused?
The firm can withdraw before a decision. A refusal is recorded and affects future applications, so take advice early.
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.
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