SMCR: UK FCA extends implementation periods for solo-regulated firms

The UK Financial Conduct Authority (FCA) has extended the deadline for solo-regulated firms to undertake their first assessment of the fitness and propriety of their certified persons under the senior managers and certification regime (SMCR) from 9 December 2020 until 31 March 2021. The FCA's intention is to provide relief to firms significantly affected by COVID-19 and give them time to make the changes they need.

The FCA intends to consult, alongside the parliamentary process for expedience, on extending the deadline for the following requirements from 9 December 2020 to 31 March 2021:

  • the date the Conduct Rules in the FCA Handbook come into force;
  • the deadline for firms to submit information about Directory Persons to the Register; and
  • references in its rules to the deadline for assessing certified persons as fit and proper (which has been agreed by HM Treasury).

Firms should continue with their programmes of work in these areas and, if they are able to certify staff earlier than March 2021, they should do so.

Where a firm considers a member of staff is not fit and proper for their certified role, the FCA stresses that the firm should not delay removing them from that certified role. 

The FCA will still publish details of certified employees of solo firms on the Financial Services Register from 9 December 2020. Therefore, where firms are able to provide this information before March 2021, the FCA encourages them to do so.

Next steps

Firms will welcome this extension in the current climate.

Hogan Lovells can help with all steps in the SMCR process, whether you are seeking authorisation or already authorised and arranging your certified persons assessments and training.

Please contact us for more information.


Authored by Michael Thomas and Yvonne Clapham.

Michael Thomas
Anahita Patwardhan
Senior Associate
Rita Hunter
Senior Associate


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