The FCA will take a proportionate approach, reflecting the diversity of firms within the proposed regime’s remit.

On 26 July 2017, the FCA published its long-awaited Consultation Papers on the extension of the Senior Managers and Certification Regime (SMCR) to all authorised firms. The “main” paper (“Individual Accountability: Extending the Senior Managers & Certification Regime to all FCA Firms” — Consultation Paper 17/25 (the Paper)) does not cover the FCA’s proposals for insurers, which are covered separately in Consultation Paper 17/26. The FCA states that the operational aspects of the new regime (including how firms will transition to the new regime, and the template for Statements of Responsibilities and the process for submitting them) will be consulted on separately in a third technical consultation paper.