New Process, Same Accountability: SMCR Compliance in 2026

The FCA’s PS26/6 policy statement, which introduced the first formal phase of SMCR reform, was widely covered as an administrative relief measure. Longer submission windows. Fewer duplicate certifications. A revised 12-week rule for senior manager transitions. Directory update timelines extended. 

All of that is true – but that doesn’t mean there’s less to do, and it certainly doesn’t mean accountability expectations have eased.   

Here is the shift that matters: before the proposed reforms, your FCA submission was, in practice, your primary compliance artefact. The act of submitting an updated Statement of Responsibilities (SoR) or Management Responsibilities Map (MRM) demonstrated, at that moment, that your governance documentation was accurate. The submission cadence created a natural forcing function for record discipline. 

Now, firms can submit SoR and MRM updates only once per six-month window, rather than notifying every change as it occurs. The submission cadence has slowed. But the governance activity – the responsibility reassignments, the structural changes, the acting-up periods – has not. And the FCA’s expectation that those changes are documented accurately, in real time, has not changed either. 

What has changed is where the evidence now needs to live. 

The submission used to be the evidence. Now, the internal record is the source of truth. For example, firms may now submit only the latest version within a six-month window, rather than notifying every change as it occurs. The obligation to have accurate SoRs and MRMs is unchanged. The reporting window has extended. 

The administrative scaffolding has been lightened. The accountability foundation has not moved. 

The 6-month SoR/MRM window shifts risk from submission to record-keeping  

The new six-month window is genuinely useful. It removes the friction of real-time notification for every governance change. But it does not remove the obligation to track those changes as they happen. 

If a responsibility shifted in month two and you are submitting in month six, your internal records need to show a clear, timestamped account of what changed, when, and why. Any misalignment between your internal records and what you ultimately submit increases regulatory risk — because it suggests your documentation is being constructed at submission time rather than maintained in real time. 

Under the old cadence, the submission was the discipline. Under the new cadence, the discipline has to come from within. Firms that do not build that internal discipline are carrying an audit risk they did not have before. 

Practical question to ask now: If the FCA asked to see the governance position at your firm on a specific date three months ago, could you produce a timestamped, accurate account of who held what responsibility, who was acting up, and what changes had occurred since the previous submission? If the honest answer is no, that is a gap that needs closing. 

How Comply Supports SMCR Best Practice

Comply Accountability is purpose-built for the governance standard needed. For firms under SMCR, it provides: 

• Full version control and timestamped audit trail for Statements of Responsibilities and Management Responsibilities Maps – so the history of every change is available for challenge, not just the current state 

• Interim governance tracking, including the 12-week temporary cover rule, with alerts for acting-up arrangements approaching submission deadlines and clear records of when conduct rule obligations attached 

• Fitness and propriety workflow, with automated reminders for annual reviews, a structured assessment process, and a retrievable compliance record for every certified person and Senior Manager 

When the FCA asks who was responsible for a function on a given date, and what steps they took, the answer should be in your system.

Frequently Asked Questions

What has actually changed about SMCR compliance

PS26/6 is the FCA’s first formal output from its SMCR review, and it is best understood as an administrative recalibration rather than a reduction in accountability. The key operational change is that firms no longer need to notify the FCA of every update to their Statement of Responsibilities (SoR) or Management Responsibilities Map (MRM) as it occurs. Instead, they may submit the latest version once within a six-month window.

Changes effective 24 April 2026:

• SoR and MRM submission frequency: Firms may now submit only the latest version within a six-month window, rather than notifying every change as it occurs. The obligation to have accurate SoRs and MRMs is unchanged. The reporting window has extended.
• The 12-week rule: Firms now have 12 weeks to submit a senior manager application, rather than to receive approval. Candidates may act in role until determination. Critically, Senior Manager Conduct Rules apply from day one of the interim period — not from the point of submission.
• Criminal records checks: Validity extended from three to six months. No repeat check required for internal or intragroup moves.
• Conduct Rule breach reporting: Only breaches where specified disciplinary action was taken need notifying. Clearer guidance on Senior Manager Conduct Rules 2 and 4.

Changes effective 10 July 2026:

• Enhanced firm thresholds: Approximately 30% inflation-adjusted increase. Some firms may move from Enhanced to Core status, changing their MRM and Prescribed Responsibility obligations.
• Certification regime: Approximately 15% reduction in overlapping certifications. Recertification can now be embedded into annual appraisal cycles and issued digitally.
• Directory update window: Most updates extended to 20 working days (up from seven). Leavers remain at seven days to mitigate fraud risk.

What is SMCR Phase 2 and when is it expected?

Phase 2 of the SM&CR review is a broader set of structural reforms that go beyond the administrative changes introduced in Phase 1. It is contingent on HM Treasury legislation and a further FCA consultation, which the FCA has indicated it expects to publish later in 2026. Phase 2 could include potential reform or abolition of the Certification Regime, structural changes to Senior Manager Functions, further simplification of Management Responsibilities Maps, and a broader overhaul of the FCA Directory.

The scope and timing of Phase 2 are not yet confirmed, as they depend on parliamentary time and the outcome of the FCA’s consultation process. Firms should monitor HM Treasury and FCA communications for updates.

What areas should firms watch as SMCR Phase 2 develops?

Four areas are most likely to be in scope for Phase 2, based on the FCA’s published signals. The Certification Regime is a candidate for significant reform, potentially including abolition — though this would be replaced by a revised fit and proper framework rather than removed entirely. Senior Manager Functions may be subject to structural changes, potentially altering which roles fall within scope. Management Responsibilities Maps may see further simplification beyond what Phase 1 introduced. And the FCA Directory may be subject to a broader overhaul following Phase 2 consultation. None of these changes are confirmed or timetabled at this stage.