The FCA is reforming the Senior Managers and Certification Regime (SM&CR) with a view to making it more efficient and proportionate whilst maintaining strong individual accountability. Below is a summary of the changes and clarifications that have come into effect or are planned for later this year.
Changes effective from 24th April 2026
Criminal record checks
The validity period for criminal record checks has been extended from three to six months. This should give firms sufficient time to use a criminal record check as both part of the due diligence process and the subsequent SMF . . .
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