Recent proposals to reform the UK’s Senior Managers & Certification Regime (SMCR) have created uncertainty across the industry. To explore what’s changing – and what isn’t – Comply and Trailight were joined by Dirk Young, Head of SMCR and Conduct Oversight at Jupiter Asset Management, to discuss what firms should be doing now to stay ahead.
Below are the key takeaways from the session.
SMCR reform does not mean reduced accountability
While parts of SMCR may become less burdensome over time, the core principles of individual accountability remain firmly in place.
Senior manager responsibilities, reasonable steps, fitness and propriety assessments, and responsibility mapping are all expected to continue for most firms. In fact, as regulation becomes less prescriptive, regulators are likely to place greater reliance on firms’ internal judgement – putting greater strain on a firms governance and evidence.
The implication for firms is clear: accountability expectations are not going away, they are evolving.
Non-financial misconduct is now central to conduct frameworks
One of the most significant developments discussed was the formal inclusion of non-financial misconduct within conduct rules and fitness and propriety assessments.
Harassment, bullying, intimidation, and similar behaviours must now be considered alongside financial misconduct when assessing individual conduct and suitability. This applies not only to senior managers, but across the regulated population.
Firms will need to:
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Update conduct and disciplinary frameworks
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Ensure consistent assessment and escalation
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Train staff and managers on expectations
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Evidence decisions fairly and consistently
This represents a material shift in how conduct risk is defined, assessed, and governed.
Fragmented and manual processes create real governance risk
As regulatory expectations shift towards supervision and outcomes, manual or siloed SMCR processes are becoming a material risk.
During the session, it was clear that accountability and conduct data often sits across multiple functions – compliance, HR, risk, legal – making it difficult to form a complete and reliable picture.
Firms relying on spreadsheets, point solutions, or in-house builds may struggle to:
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Evidence reasonable steps
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Provide timely, accurate MI to senior managers
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Respond confidently to supervisory reviews
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Identify trends and emerging risks
Automation and aggregation are increasingly essential to effective oversight.
Future-proofing accountability requires joined-up thinking
Looking ahead, the most resilient firms are treating SMCR not as a standalone obligation, but as part of a wider accountability, conduct, and employee risk framework.
This means:
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Connecting SMCR with other aspects of employee compliance
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Ensuring data can be easily accessed and aggregated
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Supporting senior managers with clear, auditable evidence
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Using technology that can adapt as regulation evolves
As the regime becomes less prescriptive, strong internal controls and scalable systems will matter more than ever.