When the Financial Conduct Authority (FCA) published Policy Statement PS26/6 in April 2026, it marked the start of the most significant review of the Senior Managers & Certification Regime (SM&CR) since its introduction.
The message from the regulator was clear: SM&CR is here to stay, but it should be easier for firms to operate without compromising accountability.
Several key implementation milestones have now passed, with most reforms already in force and further changes taking effect throughout July 2026. As firms adjust to the new requirements, many are asking the same question:
If administrative requirements have been reduced, what should firms focus on next?
A reminder of what PS26/6 is trying to achieve
The FCA’s review was driven by feedback from firms that, while SM&CR has generally achieved its objective of improving individual accountability, certain processes had become unnecessarily complex and resource intensive.
The result is a package of targeted reforms designed to make the regime more efficient and proportionate while maintaining the core principles of accountability, governance and regulatory oversight.
The reforms affect a number of areas including:
- Statements of Responsibilities
- Management Responsibilities Maps
- Certification processes
- Regulatory references
- Criminal record checks
- Conduct Rules
- Senior Management Function arrangements
- Directory reporting requirements
Most changes became effective on 24 April 2026, with additional process changes implemented in July and further conduct-related reforms scheduled for September.
July’s implementation milestones are now complete
One of the most recent developments is the completion of additional implementation phases during July 2026.
The FCA confirmed that changes to regulatory reporting and operational processes became effective on 10 July 2026, while further updates to the FCA Directory reporting framework took effect on 30 July 2026. These changes are intended to simplify reporting requirements and reduce duplication for firms and certified individuals.
While these updates may appear administrative in nature, they form part of a broader regulatory direction aimed at reducing operational burden without weakening governance expectations.
The most important message: accountability has not changed
Perhaps the most significant takeaway from PS26/6 is not what has changed, but what has remained the same.
The FCA has repeatedly stated that the fundamental principles of SM&CR remain unchanged. Individual accountability continues to sit at the centre of the regime, and firms are still expected to demonstrate clear ownership of responsibilities, effective oversight and robust governance arrangements.
In practice, this means firms must still be able to evidence:
- Who is accountable for key activities
- How responsibilities are allocated
- The status of certifications and fitness and propriety assessments
- Governance decisions and approvals
- Ongoing compliance with regulatory expectations
Reducing administration should not be confused with reducing governance.
In many ways, regulators may now expect firms to demonstrate these outcomes more efficiently and with greater clarity than before.
Why technology and governance platforms matter more than ever
As the regime becomes simpler in some areas, firms that continue to rely heavily on spreadsheets, disconnected processes and manual record keeping may find it increasingly difficult to demonstrate compliance efficiently.
The reforms create an opportunity to review how accountability and governance are managed across the organisation.
A centralised approach can help firms:
- Maintain accurate responsibility records
- Manage certification workflows
- Track approvals and attestations
- Support Conduct Rules compliance
- Produce evidence quickly during regulatory reviews
- Improve visibility across Compliance, Risk, HR and Senior Management teams
The FCA’s reforms are ultimately about making governance work better. Firms that use the opportunity to simplify and modernise their processes are likely to realise the greatest operational benefits.
September requirements should already be on your horizon
Although much of the attention has focused on the April and July implementation dates, another important milestone is approaching.
The FCA has confirmed that changes linked to non-financial misconduct requirements will come into effect on 1 September 2026 as part of the wider regulatory framework. Firms should therefore ensure their conduct frameworks, policies, training programmes and governance arrangements are appropriately aligned ahead of implementation.
For many organisations, this may require a broader review of how conduct issues are identified, escalated and evidenced within existing SM&CR processes.
Looking ahead to Phase 2
PS26/6 represents only the first phase of the FCA’s broader SM&CR review programme.
The regulator has indicated that, subject to HM Treasury’s wider legislative proposals progressing, a second phase of consultation on more substantial reforms is expected later in 2026.
While the details remain to be confirmed, firms should view the current reforms as the beginning of a wider evolution of the accountability framework rather than the final destination.
Final thoughts
PS26/6 has delivered what many firms have been asking for: a more proportionate approach to SM&CR administration without compromising the principles that underpin the regime.
However, the reforms do not lessen the need for strong governance. If anything, they create an opportunity for firms to focus less on administration and more on demonstrating effective accountability, oversight and regulatory compliance.
The firms that benefit most from these changes will be those that use them as a catalyst to streamline processes, strengthen governance visibility and ensure accountability remains clearly evidenced throughout the organisation.
SM&CR may be becoming simpler, but accountability remains as important as ever.
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