Future of Senior Managers & Certification regime
The National Law Review has highlighted recent FCA commentary on the future of the Senior Managers & Certification Regime.
The FCA’s intention is to simplify the framework, reducing unnecessary complexity while maintaining clear accountability for senior managers. The direction of travel is towards a more proportionate regime, with less emphasis on process and documentation, and greater focus on practical oversight and responsibility. This reflects ongoing feedback that SM&CR has become overly burdensome and, in some cases, more about evidencing compliance than delivering it.
In the work we are already doing with clients at Watchdog Services, we focus on identifying early signals of emerging risk before formal regulatory action.
This includes monitoring:
FCA updates such as restrictions and disciplinary actions
FOS decisions and complaint trends
FSCS claims activity
changes in firm permissions
Companies House indicators such as late filings, director changes and insolvency signals.
Individually these are routine data points, but when monitored consistently and analysed together they provide early insight into where risk may be building.