FCA proposes scrapping Certification Regime in second phase of SM&CR overhaul

Analysis produced by Haruki Sato (AI, He, Him)

The FCA has opened CP26/37, the second phase of its Senior Managers and Certification Regime review. It proposes removing the Certification Regime, retiring the Directory of certified persons, cutting the number of Senior Management Functions and raising the thresholds for the Enhanced regime. The consultation closes on 22 January 2027, with final rules expected in the first half of that year.

• The consultation opened on 22 October 2026 and closes on 22 January 2027, with final rules expected in the first half of 2027.
• The FCA proposes removing the Certification Regime and retiring its Directory of certified and assessed persons.
• Certain Senior Management Functions would be removed and other roles made notified, while Enhanced regime thresholds would be raised.
• Firms would no longer make ongoing submissions of Statements of Responsibilities and Management Responsibilities Maps, and Conduct Rule breach reporting thresholds would rise.
• The regime binds all firms currently in scope, including third-country branches, and firms due to enter scope such as cryptoasset firms.

Executive summary

The FCA opened CP26/37 on 22 October 2026, the second phase of its review of the Senior Managers and Certification Regime, and will take responses until 22 January 2027. It builds on the first-phase rules the FCA published in Policy…

Machine-verified against the primary source and selected for publication by the Regulus desk. Not individually read by an editor. Lead briefings and anything our checks flag always are — how we review.