The UK SMCR & Enforcement Investigations


In a recent letter to CEOs, the FCA talked about the importance of robust governance frameworks that allow cultures and values to drive decision-making across the business; and how critical it is for firms to be managed by effective boards with a suitable mix of skills and experience in order to conduct proper oversight of the firms' risks, strategies, policies and controls.

There is an increased focus by regulators on governance, culture, and individual accountability for financial services in the UK, Ireland, Hong Kong, Australia and Singapore. Although countries have different regimes, the focus is on improving individual accountability through a healthy culture and effective governance.

In the UK the SMCR introduction was driven by a perceived lack of individual accountability and governance failings post-financial crisis. For most solo-regulated firms, the SMCR was applied in 2018, and a similar regime for banks and insurers has applied since 2016. The original SMCR deadline in December 2020 was extended to March 31 due to Covid-19, which gave senior managers and staff extra time to prepare.

The foundation of the Senior Managers Regime is the requirement for firms to submit a statement of responsibility. The statement of responsibility sets out the complete list of senior management functions (SMFs), covering every significant aspect of a firm's operations, and senior managers must accept its responsibility for managing the role.

Implementing the SMCR is a continuous process and needs attention from now on as firms should be considering how their implementation can be tested and enhanced. In addition, compliance must have effective governance and oversight arrangements in place to meet the firm's regulatory obligations. 

MCO and Gowling WLG hosted a webinar that explores the current hot topics relating to SMCR from both a regulatory and employment perspective. The agenda includes:

  • SMCR in the context of climate change
  • Non-financial misconduct
  • Enforcement investigations

Register to watch on-demand now!

This webinar was recorded on May 12, 2021. 

Would you like to know more about the topic? Look at the blogs below or visit Gowling WLG to listen to their SMCR series of podcasts.

How is Climate Change Impacting on the Financial Services Sector?

The Developing Regulatory Approach to Climate Change and the importance for Financial Services

SFDR Explained: Actions for Asset Managers and Investment Advisors



Principal Associate, UK Financial Services Regulation at Gowling WLG

For full bio, please access Sushil Kuner profile at Gowling WLG.


Partner, Head of UK Financial Services Regulation and Joint Head of UK Financial Services Sector at Gowling WLG

For full bio, please access Ian Mason profile at Gowling WLG.


Legal Director at Gowling WLG

For full bio, please access Simon Stephen profile at Gowling WLG.

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Gowling WLG is an international law firm created by the combination of Gowlings, a leading Canadian law firm, and Wragge Lawrence Graham & Co (WLG), a leading UK-based international law firm.

With more than 1,400 legal professionals in 19 cities worldwide, Gowling WLG provides in-depth expertise in key global sectors and a suite of legal services at home and abroad. Gowling WLG see the world through clients’ eyes, and collaborate across countries, offices, service areas and sectors to help customers succeed, no matter how challenging the circumstances.