The Senior Managers and Certification Regime (SM&CR) increases management's accountability for the business areas they are responsible for. The regime has already helped to foster good conduct in firms across the UK, to the benefit of customers and markets. 

Our extensive experience in supporting banking, insurance and other regulated firms through previous rounds of implementation will help you achieve, and maintain, compliance quickly and effectively. 


Our SM&CR Suite covers all key areas of compliance, ensuring your firm is fully prepared to implement the new regime and maximise the operational and commercial benefits it brings. 

The elements of the suite can be combined as part of a holistic, Huntswood-managed programme or be undertaken individually, depending on your firm’s requirements:


We will undertake an in-depth review of the following areas to inform your firm’s future SM&CR approach:

  • Organisational structure and reporting lines
  • The role and make-up of individual committees, including their terms of reference
  • Governance arrangements and your firm’s operating model
  • Content and distribution of management information (MI)

Taking lessons learned from our initial review, we will develop a project plan tailored specifically for your firm. This will involve:

  • Identifying and allocating Senior Manager Functions (SMFs)
  • Recommending which individuals at the very top of the organisation have ultimate responsibility for certain prescribed responsibilities
  • Articulating how these responsibilities map to Statements of Responsibilities and Responsibilities Maps
  • Putting in place the process needed to certify individuals and ensure they are ‘fit and proper’ to perform their role
  • Identifying the most efficient and effective approach to integrating SM&CR into your current operating model and policy framework
  • Planning out how to best execute firm-wide change

If required, our SM&CR project managers can support your team to execute the actions that will ensure a successful and timely implementation. This might include engaging relevant stakeholders, setting timelines and managing the implementation plan.

We can also provide assurance on governance and committee structures, the allocation of roles and putting together regulatory documentation.

Our SM&CR Toolkit includes key templates and guidelines for developing documentation that meet, exactly, FCA requirements. This includes:

  • A project plan covering all required work streams
  • Responsibilities Maps and Statements of Responsibilities
  • Annual ‘fit and proper’ policy and certification procedures
  • Handover policy and certificates
  • Defining ‘reasonable steps’ and creating ‘living wills’
  • Breach reporting policy

Our SM&CR Academy includes tailor-ready workshops and e-Learning courses that support employees, at all levels through the transition to SM&CR.

Senior Management Function workshop

This full-day workshop helps to ensure the SMF population understands the impact of the new Regime on them personally, their responsibilities, and how they undertake their day-to-day roles.

This full-day programme is designed to meet requirements for training on the Conduct Rules.

Certified Individual (CI) workshop

This half-day workshop will help ensure the CI population understand the impact of new rules on their responsibilities and the practical steps they need to undertake to ensure compliance.

This programme meets the requirements for training on the Conduct Rules.

E-Learning Module

This module provides a base level of knowledge to staff about SM&CR and the obligations it places on firms and individuals.

Completion of e-Learning, when combined with a structured coaching conversation, meets the requirements for training on the Conduct Rules.

Why Huntswood

  • We’ll provide assurance on your firm’s implementation plan and ongoing compliance with the regulation
  • Our SM&CR specialists will always be at your side when you need them, able to guide training that will set your teams and managers on the path to success
  • We'll provide detailed guidance on how to write Statements of Responsibility, Responsibilities Maps and other formal items that are required by the FCA
  • Your firm will benefit from a post-implementation review that will provide clarity on the success of your approach

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Huntswood didn't go off track at all with any part of the delivery and fully understood our business. If any compliance / conduct risk support is required, Huntswood will always be involved in the process.

Motor Finance provider

The Huntswood team have delivered precisely to brief and in a timely manner too. I have been most pleased with the thoroughness of preparation going into the project. This, combined with the obvious regulatory and strategic experience you all have, has made the project a great success.

Managing director, major insurance firm

The high levels of engagement and expertise you have provided ensured we were well informed, consulted and guided (where appropriate) … The collaborative approach was excellent and created trust and understanding around the new model. Not only was this invaluable for the team, it was beneficial for the wider business …

Head of Quality, large general insurance intermediary