Well, let’s start by saying that 2021 surely can’t be any more challenging than 2020?!
That said, now that the majority of HR and Compliance practitioners in firms will be punching the air and (hopefully) congratulating themselves on a job well done through their first round of Certification and Directory uploads, here comes the real challenge. Managing the regime in BAU in a way that: a) doesn’t cause a huge administrative overhead and b) demonstrates to the regulator that you are complying to the legislation and maintaining a solid audit trail and record keeping regime to prove it.
Half the challenge is in identifying exactly where SMCR sits in your organisation. Having worked with hundreds of banks, investment firms, insurers and consumer credit firms on their SMCR projects, one thing has remained consistent – there isn’t a great deal of consistency. And I certainly don’t mean that disparagingly; on the contrary, the regime is intended to be embedded with the “spirit” of the regime and therefore leaves a little room for manoeuvre on who holds the reins. HR? Compliance? Risk? All of the above? What works for one firm won’t be the same for others and 2021 will no doubt see a bit of moving and shaking in this regard as the realisation of the ongoing management becomes real.
In terms of SMCR systems and processes (as an SMCR systems provider, something would be amiss if I didn’t mention it!) activity in 2021 is likely to be a mixed bag. Banking firms who adopted solutions, either in-house built or via a 3rd party, early on in the inception of SMCR in 2016, are likely to be reviewing or renewing their arrangements for their fitness and propriety and cost-effectiveness. For those that are new to the regime, this is a period of reflection and planning and surveying the options available to them.
On a personal level, whilst Worksmart continues apace with numerous Accord implementations, I am seeing many firms being forced to re-prioritise projects due to the impact of the Covid 19 Pandemic, where HR system replacement has become king as weaknesses were exposed in them in 2020 with staff working from home, wellness agendas etc. My big fear in this regard is that firms may be enticed by promises from HR system vendors that their functionality will manage the regime – indeed, where we have seen this happen, it is invariably untrue or exaggerated with a “back to the drawing board” outcome!
That said, SMCR systems acquisition remains a strong budgetary contender and in most cases will remain a 2021 project, just a little later than planned. Having something in place for the next round of Certification seems to be driving interest. “I’m not going through that again” has become a commonly voiced view!
A number of Worksmart’s customers also have operations in Singapore, Australia and Ireland, where regimes similar to SMCR loom, with Singapore’s IAC regime coming into force in September this year. Needless to say, Worksmart is prepared for this and looking forward to welcoming Singaporean clients new and old!
So my predictions for 2021 in summary:
- SMCR system adoption will exceed that of 2020
- Reflection and amendment of Certification processes
- Mistakes may be made
- Overseas regimes will drive a global approach to accountability
If you would like to know more about how Worksmart’s RegTech solutions suite could help transform your response to people based regulation, contact our friendly and knowledgeable team on: 01908 613613 or email us on: info@worksmart.co.uk