How to Manage Individual Accountability Across Entities and Jurisdictions

Accountability requirements from one region to another are often managed in silos, and usually viewed from a regional perspective.

For firms operating across multiple entities — whether that’s a UK-headquartered bank adding an Irish subsidiary under IAF, an Australian group navigating the Financial Accountability Regime (FAR) alongside UK SMCR obligations, or a European institution preparing for CRD VI accountability requirements alongside those of their National Competent Authority — the compliance challenge is the same: each regime places direct, personal responsibility on named senior individuals, and no two regimes do it in exactly the same way.

A holistic, multi-jurisdictional view of individual accountability that spans jurisdictions supports global reporting, analysis, and risk management. What’s more, it empowers consistent values which drives better governance across the organisation and all its sites.

A holistic view of compliance

In recent years, individual accountability regimes have been introduced across the globe. Although these regimes share common values — such as standards for individual conduct and a focus on positive outcomes for customers — they each introduce a complex web of detailed requirements. Financial services organisations have been spending the past few years adapting their processes and compliance frameworks in line with these new demands.

The key regimes now shaping the global accountability landscape include:

• The UK’s Senior Managers and Certification Regime (SMCR): The most established individual accountability regime globally, SMCR has applied to all FCA-regulated firms since 2019 and is jointly overseen by the FCA and PRA. It requires Senior Managers to hold documented Statements of Responsibilities, firms to maintain a Management Responsibilities Map, and Certified Persons to undergo annual fitness and propriety assessments. For many multi-entity firms, SMCR is the baseline against which other regimes are measured — and the starting point from which cross-border accountability frameworks are built.
• Ireland’s Individual Accountability Framework (IAF) and Senior Executive Accountability Regime (SEAR): Introduced by the Central Bank of Ireland under the IAF Act 2023, SEAR has applied to executive pre-approval controlled functions (PCFs) since 1 July 2024, and was extended to non-executive directors and independent non-executive directors (NEDs/INEDs) from 1 July 2025. In-scope firms must produce Statements of Responsibilities and a Management Responsibility Map, with responsibilities categorised as Inherent, Prescribed, or Other.
• Australia’s Financial Accountability Regime (FAR): Jointly administered by APRA and ASIC, FAR replaced the Banking Executive Accountability Regime (BEAR) and came into force for authorised deposit-taking institutions (ADIs) from 15 March 2024, extending to insurers and superannuation trustees from 15 March 2025. It introduces four core obligation sets: accountability obligations, key personnel obligations, deferred remuneration obligations, and notification obligations — with named accountable persons registered on a public FAR register.
• The EU’s Capital Requirements Directive VI (CRD VI): In force from January 2025 and due for full transposition by EU Member States by 10 January 2026, CRD VI introduces SMCR-style individual accountability requirements for in-scope banks. Under Article 88(3), management body members, senior managers, and key function holders must each have documented Statements of Role and Duties, supported by a comprehensive mapping of duties across the organisation.
• Switzerland’s Senior Management Regime (SMR): Proposed by the Swiss Federal Council in its April 2024 banking stability report — prompted in part by the collapse of Credit Suisse — the SMR would require systemically important banks (SIBs) and potentially other financial institutions to formally assign and document responsibilities at senior management level, with obligations submitted to FINMA. Draft legislation is expected in the first half of 2026. For global firms with Swiss entities, forward planning now will avoid a last-minute implementation scramble.

This has been a long road for companies dealing with one regime, never mind multi-national organisations who have had multiple regimes to implement. Regulators manage different regulated entities separately, which doesn’t always align with the global needs, compliance frameworks, and data systems of the organisation.

Looking at population trends

Whether organisations have entities in one region or multiple, they need to be able to track individuals — and their accountability obligations across each regime — as well as themes across a population. They should also be able to report on these different views with completeness and compatibility.

In specific circumstances, an organisation may want to zoom out and look at accountability trends across an entity or all jurisdictions. This allows them to understand widespread systematic risks and challenges, or the impact of regulatory processes.

Organisations may struggle to do this if they are using separate systems, as regional solutions won’t be recording the same data in the same way. For example, a firm managing UK SMCR in one system, Ireland IAF/SEAR in another, and FAR obligations in a third will find it almost impossible to produce consolidated reporting or identify compliance gaps that span entities.

To do this effectively — and not entirely manually — organisations need a unified solution which not only tracks all their individual compliance activity but can flexibly navigate through it to understand compliance across all in-scope regimes and entities.

Working across regions

There are various scenarios where individuals may be working across borders. This may be employees collaborating from different sites or jurisdictions, sharing data between regulated entities, or working with clients in another region.

In these scenarios, any process being followed for a shared project or communication needs to be compliant for both regions. Having a unified system that can show the requirements for any individual involved in a project — regardless of where they are — will better support organisations to manage this work compliantly.

Consider a senior manager who holds a role across both a UK entity subject to SMCR and an Irish entity subject to SEAR. Both regimes require Statements of Responsibilities, but the categories of prescribed responsibilities differ, and the reporting obligations on suspected breaches are not the same. Without a system that understands both frameworks, it is easy for coverage gaps or duplicated effort to go undetected — and for individual accountability to become a paper exercise rather than a lived governance standard.

The common thread across all individual accountability regimes

Underpinning all regional or individual requirements are universal themes. No matter the location or organisational structure, having good competence, conduct, and culture is essential for good governance. Whether a firm is implementing Statements of Responsibilities under UK SMCR, Accountability Statements under FAR, or the new duty-mapping requirements of CRD VI, the underlying expectation from regulators is consistent: named individuals must be able to demonstrate what they are responsible for, what decisions they made, and what steps they took.

Having a robust system in place helps build transparency and consistency across regional requirements so that organisations are empowered to establish these pillars of governance across entities or jurisdictions. By having all individual data in one place, organisations can better gain visibility over individual activity, reduce risk, and foster positive trends throughout their populations.

How Comply Accountability supports multi-regime, multi-entity firms

Comply Accountability is purpose-built for firms operating across multiple individual accountability regimes — whether that’s SMCR, Ireland’s IAF and SEAR, Australia’s FAR, CRD VI across EU Member States, or others. Rather than managing each entity’s obligations in isolation, Comply Accountability gives compliance teams a single, structured platform to:

• Map and maintain Statements of Responsibilities, Accountability Statements, and duty-mapping documentation for every in-scope individual across all entities
• Track fitness and propriety obligations, certifications, and conduct records — with full version control and timestamped audit trails
• Zoom out to identify accountability gaps or population-level trends across jurisdictions, or drill down to monitor individual activity at entity level
• Respond to regulatory inquiries with confidence — not manual scrambling through shared folders and disconnected spreadsheets

As accountability regulation continues to spread and deepen globally, the operational burden of managing multiple regimes manually is no longer sustainable. The firms that will navigate this environment most effectively are those that treat multi-jurisdictional accountability as a unified governance challenge — not a series of separate compliance tasks.

Find out how Comply Accountability supports firms across SMCR, SEAR/IAF, FAR, CRD VI and more regimes. Book a consultation.