Extending the Senior Managers and Certification Regime (SMCR) to General Insurance - Searchlight Insurance Training

Extending the Senior Managers and Certification Regime (SMCR) to General Insurance

The Senior Managers and Certification Regime (SM&CR) – currently applied to banks and insurers – will be extended to all FCA solo regulated firms from December 2019, when it will replace the Approved Persons Regime (APR). For insurance intermediaries, this is the biggest change to regulatory governance since 2005.

There are significant differences between APR and SM&CR, particularly in relation to obligations for:

  • A statutory duty of responsibility for senior managers
  • The Certification Regime,
  • The wider application of Conduct Rules.

Its intention is for clear and transparent accountability at the most senior levels of any firm whilst extending responsibility for customer outcomes down through a firm.

“…promote positive behaviours that reduce harm”

“…improve individual accountability and the awareness of conduct issues across the firm”

FCA Guide to SM&CR for solo regulated firms

Much of SM&CR is the natural evolution of good, documented, governance. Well-run firms, who have complied with APR, will already have many of the processes, effective performance management and a conduct culture of accountability in place.

This course will equip individuals to manage the transition through understanding SM&CR: what is new and different, what is actually similar and what is a realistic gap analysis of where the firm is now and what must be place by December.

Level: n/a

Duration: 0.5 day(s) CII CPD Hours: 3


By the end of this workshop delegates will be able to:

  • Summarise and appreciate the drivers of the SM&CR
  • Position your firm within the proportionate scope of SM&CR and the associated obligations
  • Identify your likely Senior Manager and Certification Functions
  • Explain the allocation of functions and prescribed responsibilities and the essential documentation
  • Describe where and how the fit and proper requirements apply and how you will maintain them
  • Describe how the conduct requirements are extended by SM&CR, and how you will apply them
  • Review the transition time line and consider your action plan for transition

Searchlight can provide post-course consultancy services to those firms who believe that they may need specialist help in understanding and addressing SMCR requirements – for example, undertaking a gap analysis to determine how well the firm’s current arrangements match the new requirements and providing assistance to address issues that are identified.


  • The backdrop: good corporate governance
  • The drivers, evolution and objectives of SM&CR
  • The structure of SM&CR for core, enhanced and limited scope firms, and how it compares with the Approved Persons regime
  • The Senior Manager Function and the implications of the statutory duty of responsibility
  • Documenting SM&CR: e.g. prescribed responsibilities and statements of responsibilities
  • Who are your Certified Functions and what are the obligations?
  • Testing fitness and propriety of staff under the new regime
  • Interpreting, applying and demonstrating the extended Conduct Rules
  • Identifying new, or changes to existing systems which will be needed
  • Gap analysis and action planning