The Financial Conduct Authority proposes removing the Certification Regime and associated Directory as part of the second phase of its SM&CR review. The consultation opened on 22 October and closes on 22 January 2027. Legislative dependencies and final rulemaking remain before implementation.[1][2]
Main proposals and their boundaries
| Area | Proposal |
|---|---|
| Certification and Directory | Remove these processes; retain relevant competence and suitability dutiesSource 1Source 2 |
| Senior management functions | Streamline functions and approval or notification requirementsSource 1Source 2 |
| Enhanced firms | Raise the thresholds determining enhanced statusSource 1Source 2 |
| Responsibility documents | Remove routine submission of some updated statements and mapsSource 1Source 2 |
| Conduct requirements | Review training and reporting requirementsSource 1Source 2 |
| Next formal step | Policy statement expected in H1 2027Source 1Source 2 |
Less certification does not remove responsibility for staff
The consultation distinguishes a prescribed certification process from the wider obligation to ensure staff are competent and suitable. Its discussion of alternatives and existing requirements is therefore central to interpreting the headline. It does not say that firms can dispense with recruitment controls, supervision or conduct oversight.[2]
For implementation planning, the useful unit is the process that would change: who assesses a role, what evidence is retained, which approval or notification applies, and which obligations continue. Removing a scheduled document or submission does not answer all of those questions.
The proposal also depends on the legislative framework considered in the Financial Services and Markets Bill. Firms should distinguish the consultation’s preferred approach from the final legal text and commencement arrangements. The published response deadline is the next confirmed public milestone; the first-half policy-statement timing remains an expectation.[1][2]
Sources & further reading
- CP26/37: Senior Managers & Certification Regime review — phase 2 Financial Conduct Authority · 22 Oct 2026 · Accessed 27 Oct 2026
- CP26/37 consultation paper, including proposed changes and cost-benefit analysis Financial Conduct Authority · 22 Oct 2026 · Accessed 27 Oct 2026