In October 2021, the FCA announced that it was considering extending the Senior Managers and Certification Regime (SMCR) to FMIs, payment and e-money firms. In what will be the third extension of the SMCR since 2016, a further 600 firms will be required to implement and comply with the requirements of the SMCR.

Although it may be premature to prepare for implementation right now as the specific details of how the SMCR will apply to these types of firms have not been confirmed, it is not too soon to think ahead to how you are set up and how you run your business, in order to put your firm in the best possible position when those details are announced. Since all iterations of SMCR have been about accountability, it makes sense to start thinking about whether roles and internal reporting lines are clearly defined and whether existing governance arrangements are clear and operating effectively. It is also worth looking at your recent pulse and annual workforce surveys to see what they are saying about the culture of your firm. This is an area in which the FCA is particularly interested as it sees healthy cultures as driving better conduct and better business decisions. Are there enhancements that you could be making in these areas sooner rather than later?