The Financial Conduct Authority (FCA) has today published its final rules on the extension of the Senior Managers and Certification Regime (SMCR) to the majority of FCA solo-regulated firms. In general, the FCA has implemented the proposed changes to the SMCR as consulted on. The main changes to the FCA's existing rules include:

  • confirming that the Head of Legal function is not required in Senior Managers Regime;
  • amending the intermediary revenue criterion for the Enhanced regime;
  • clarifying the requirements and scope of the Certification Regime (in particular, the scope of the Client Dealing Function and the application of the Systems and Controls roles); and
  • extending Senior Manager Conduct Rule 4 (SC4) to non-approved Executive Directors at Limited Scope firms.

Firms now have until 9 December 2019 to implement the final rules, although certain rules will be phased-in over time, and ensure that they are compliant with the new regime.