Governance for the Individuals Regulators Hold Responsible

Comply Accountability is available today as a standalone solution and is being progressively integrated into the broader Comply platform. In the first phase, users access Comply Accountability through single sign-on (SSO) alongside their existing Comply tools. In the next phase, accountability data will be surfaced directly within the Comply employee profile — giving compliance teams a single view of an individual’s obligations, accountability records, and compliance activity in one place. For firms already using Comply, this means your SMCR and accountability obligations will sit alongside your existing employee compliance program without the need for separate logins or manual data reconciliation.

Yes. SMCR is the foundation the platform was built on. Comply Accountability supports the full scope of Senior Managers and Certification Regime obligations — including Senior Management Function mapping, Statements of Responsibilities, Management Responsibility Maps, fitness and propriety assessments, certification workflows, conduct rule attestations, and the evidencing of reasonable steps. For firms subject to the FCA’s enhanced, core, or limited scope regime, Comply Accountability structures and automates the workflows that SMCR demands, and retains the evidence regulators expect to see when they come asking.

An Individual Accountability Regime is a regulatory framework that places direct, personal responsibility on named senior individuals within financial services firms — rather than holding the firm as a collective entity accountable. The FCA’s Senior Managers and Certification Regime (SMCR) is the most well-established example, but regulators around the world have followed suit. Ireland introduced the Senior Executive Accountability Regime (SEAR), Australia implemented the Financial Accountability Regime (FAR), Singapore published the Monetary Authority of Singapore’s Individual Accountability and Conduct guidelines, and Hong Kong operates the Manager-in-Charge (MIC) regime. The common thread across all of them is the same: specific individuals must be able to demonstrate what they were responsible for, what decisions they made, and what steps they took. Firms that cannot evidence this at the individual level (not just the firm level) face significant regulatory exposure.

Yes. Comply Accountability is available as a standalone platform for firms that need dedicated individual accountability governance, regardless of whether they use other Comply products. It is particularly well suited to firms that already have employee compliance tooling in place but lack the depth of structure required for SMCR, SEAR, FAR, or equivalent regimes at the senior manager level. For firms using the broader Comply platform, Comply Accountability will progressively integrate to provide a unified view of individual obligations across both employee compliance and accountability governance.

A Statement of Responsibilities is one of the most operationally demanding documents under SMCR. Every Senior Management Function holder must have a current, accurate SoR that clearly sets out what they are personally responsible and accountable for. The challenge is that SoRs are live documents — they change when individuals move roles, when the firm restructures, or when regulatory requirements evolve. Managing them manually across a large firm is a significant compliance risk. Comply Accountability centralizes SoR creation, assignment, and version control within a single platform. Changes are tracked and time-stamped, delegation mandates are recorded, and the full history of every SoR is retained as evidence. When the FCA asks to see a senior manager’s responsibilities at a specific point in time, firms using Comply Accountability can produce that record immediately.

A Management Responsibility Map is a firm-level document required under SMCR that sets out the governance and management structure of the firm — showing how responsibilities are allocated across senior managers, where reporting lines sit, and how the firm is run day to day. For enhanced firms in particular, the MRM must be kept current and submitted to the FCA as part of the firm’s regulatory obligations. In practice, keeping an MRM accurate is one of the most challenging aspects of SMCR governance — organizational structures change, senior managers move, and responsibilities shift. Firms that manage this in spreadsheets or static documents invariably find their MRM drifting out of date. Comply Accountability structures the MRM within the platform, linking it directly to live role assignments and SoRs so that changes to an individual’s responsibilities are automatically reflected in the broader governance map. This means the MRM is always current, always evidenced, and always ready for regulatory scrutiny.