How to Apply to Become an FCA Approved Person or Senior Manager under SMCR

Feb 16 2025

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How to Apply to Become an FCA Approved Person or Senior Manager under SMCR

FCA Approved Person or Senior Manager : The Financial Conduct Authority (FCA) plays a critical role in ensuring that individuals holding key positions in regulated firms are fit and proper to perform their duties. Whether you’re applying to become an FCA Approved Person in a non-SMCR firm or seeking Senior Management Function (SMF) approval in a firm operating under the Senior Managers and Certification Regime (SMCR), understanding the process is critical for compliance and success in the financial sector.

What Does It Mean to Be an FCA-Approved Person?

An FCA Approved Person is someone authorised to carry out certain controlled functions in a non-SMCR firm. These functions involve key responsibilities, such as compliance oversight, financial control, or customer interaction. Only individuals who meet the FCA’s “fit and proper” assessment standards can assume these roles to ensure accountability and robust governance.

What Are Senior Management Functions (SMFs)?

For firms operating under the SMCR, individuals holding certain senior positions need to be approved to perform what the FCA defines as Senior Management Functions (SMFs). These are roles with significant influence over a firm’s operations, decision-making, and risk management. Examples of SMFs include the Chief Executive Officer (SMF1), Chief Risk Officer (SMF4), or Compliance Oversight (SMF16).

Unlike legacy Approved Persons, SMFs come with distinct regulatory requirements, including the implementation of a Statement of Responsibilities (SoR) and adherence to the Senior Managers’ Conduct Rules.

How to Apply as an FCA Approved Person (Non-SMCR Firms)

Identify the Relevant Controlled Function (CF)

Start by identifying the regulated activity and the corresponding CFs relevant to the firm. Examples include:

CF1: Director Function
CF10: Compliance Oversight Function
CF11: Money Laundering Reporting Officer

Fit and Proper Assessment

Show that the candidate meets the FCA’s criteria of competence, honesty, integrity, and financial soundness. This includes providing a detailed employment history and disclosing criminal or adverse regulatory records.

Submission of Forms

For non-SMCR firms, complete the FCA Form A (Application for Approved Persons) and submit it via the FCA’s Connect portal. This form requires detailed information about the individual, their qualifications, experience, and regulatory history.

Approval

Upon application review, the FCA might request additional details before granting approval. If successful, the individual will receive confirmation that they are authorised to perform their designated controlled function within the firm.

How to Apply for Senior Management Functions (SMFs) under SMCR

For SMCR-regulated firms, the application process includes stricter governance requirements compared to the traditional Approved Persons Regime.

Identify the SMF Role

Determine which SMF role is applicable for the individual’s position. Common SMFs include:

Chief Executive Function (SMF1)
Chief Financial Officer (SMF2)
Chair (SMF9)
Compliance Oversight (SMF16)
Other key SMFs as per the firm’s regulatory structure

Prepare a Statement of Responsibilities (SoR)

The candidate must outline their responsibilities clearly in an SoR document, showing how their role contributes to the firm’s compliance, governance, and control systems.

Fit and Proper Assessment

Just like with Approved Persons, candidates for SMFs must meet the FCA’s “fit and proper” standards. SMCR firms must conduct annual assessments to confirm ongoing compliance.

Complete and Submit the Form A

The individual must complete the appropriate sections of Form A via the FCA Connect portal, including submitting the SoR. Firms must also provide additional documentation to support the application, such as an organisational chart or governance structure.

Compliance Consultant can create a Suite of FCA required documents for SMF application.

Click Here FCA SMF Application and Assessment Support Service

Regulatory Reference Checks

SMCR firms must obtain regulatory references from previous employers as part of the background checks. This ensures the individual has not faced serious misconduct allegations in prior roles.

Key Differences Between Approved Persons and SMFs under SMCR

Aspect	Approved Person	Senior Management Function (SMF)
Applicability	Non-SMCR firms	Firms under the SMCR
Regulatory Focus	Controlled Functions (CFs)	Senior Management Function (SMFs)
Document Requirements	Form A application	Form A + Statement of Responsibilities (SoR)
Ongoing Responsibilities	Conduct Rules	Conduct Rules + Senior Managers’ Conduct Rules
Annual Assessment	Not mandatory	Fit and proper assessment must be conducted annually

Frequently Asked Questions (FAQs)

Who needs to apply for SMFs under SMCR?
Individuals in senior decision-making roles, such as Directors, CFOs, and Compliance Officers, in SMCR-regulated firms require FCA authorisation as an SMF.
Are all firms under the SMCR?
No, SMCR applies to banks, building societies, credit unions, insurers, and solo-regulated financial services firms. Other firms remain under the Approved Persons Regime.
How long does the FCA take to process applications?
Applications typically take three to six months, depending on complexity and the FCA’s assessment workload.
Can I apply for multiple roles?
Yes, but the FCA will assess your ability to manage multiple responsibilities within compliance and governance frameworks.