FCA PS26/6 — Senior Managers and Certification Regime review (phase 1 reforms)

Updated 2026-06-05 — publication date and final adopted rules confirmed via the daily scan (PS26/6 PDF located at fca.org.uk plus legal commentary; see Ingestion note). The earlier approximate date of 2026-05-29 is superseded by the confirmed 2026-04-22.

Tag: S-2026-05-fca-smcr-review-ps26-6 (tag retained for link stability; source’s own date is 2026-04-22) Type: report (policy statement, following consultation CP25/21) Author(s): Financial Conduct Authority (jointly developed with the PRA, whose parallel policy statement is PS12/26) Date of source: 2026-04-22 (confirmed 2026-06-05; previously approximated as 2026-05-29) Date ingested: 2026-06-01 Authority weight: high — FCA policy statement on a core accountability regime. Raw file: S-2026-05-fca-smcr-review-ps26-6.md. External URLs: https://www.fca.org.uk/publications/policy-statements/ps26-6-senior-managers-certification-regime-review and underlying consultation https://www.fca.org.uk/publication/consultation/cp25-21.pdf

What it claims

PS26/6 is the FCA’s policy statement following consultation CP25/21 (opened 15 July 2025, closed 7 October 2025) on the first phase of reforms to the Senior Managers and Certification Regime (SM&CR). The stated aim is to streamline the regime to boost competitiveness and support growth while preserving its benefits, in parallel with the PRA’s equivalent consultation for dual-regulated firms.

The phase 1 proposals (as consulted in CP25/21) include: giving firms more time and flexibility to submit applications to approve new senior managers after an unexpected or temporary change; removing duplication where the same individual is certified for separate functions — reducing the number of certification roles by ~15%; guidance to streamline the annual “fit and proper” certification checks; more time to report updates to senior-manager responsibilities; longer validity for criminal-record checks prior to application; clearer definitions of certain senior management function (SMF) roles; and more time to update the FCA Directory of certified staff. The regime applies to all solo-regulated and dual-regulated firms, including third-country branches.

In phase 2, the FCA will work with HM Treasury on legislative changes, including what should replace the certification regime and the number of senior managers subject to approval.

Final rules as adopted (confirmed 2026-06-05 via secondary legal commentary; see Ingestion note). PS26/6 was published on 22 April 2026, jointly developed with the PRA (PRA policy statement PS12/26 for dual-regulated firms), and largely reflects the consulted position. Confirmed elements include: senior manager applications after an unexpected or temporary change need only be submitted within the 12-week period; certification simplified — certification must be in writing but no paper certificate is required (an email suffices); criminal-record check validity extended from 3 to 6 months prior to application, and CRCs no longer required for internal or intragroup moves. Most changes took effect on 24 April 2026; improvements to regulatory reporting and processes apply from 10 July 2026. Commentary characterises PS26/6 as the most substantive recalibration of the SM&CR since its 2016 introduction [commentary’s characterisation, not the FCA’s].

Notable quotes

“The SM&CR has driven up standards in financial services. But we want to boost competitiveness, and support growth, by streamlining the regime while preserving its benefits.” — FCA, CP25/21 page

“Strip out duplication where the same individuals are certified for separate functions, which would reduce the number of certification roles by 15%.” — FCA, CP25/21 proposals

What’s speculative vs. asserted

• Asserted (confirmed from FCA pages): the existence and purpose of the SM&CR review; CP25/21 dates (opened 15/07/2025, closed 07/10/2025); the phase 1 proposals listed above; the phase 2 scope (certification-regime replacement; number of approved senior managers); parallel PRA consultation.
• Asserted (confirmed 2026-06-05 via secondary commentary, not the PS PDF itself): publication date 22 April 2026; PRA PS12/26; the adopted reforms and effective dates (most from 24 April 2026, reporting changes from 10 July 2026); the specific certification, CRC and 12-week application changes.
• Speculative / not confirmed: the complete final rules text — whether every consulted proposal (e.g. the ~15% certification-role reduction) was carried unchanged has not been verified against the PS26/6 PDF directly.
• Earlier view (superseded 2026-06-05): the exact PS26/6 publication date and adopted rules were recorded as unconfirmed, with source date approximated as 2026-05-29 — superseded by the confirmed details above.

Topics this feeds

• FCA approach to AI — SM&CR is the individual-accountability lever onto which AI-decision responsibilities are mapped.
• FCA — Financial Conduct Authority

Open questions raised

• Which phase 1 proposals were adopted unchanged in the final PS26/6, and from what date they take effect. Partially resolved 2026-06-05: key adopted reforms and effective dates (24 April 2026 / 10 July 2026) confirmed via secondary commentary; full proposal-by-proposal disposition still unverified against the PS PDF.
• Whether phase 2 (with HM Treasury) will retain, replace or abolish the certification regime.
• How the streamlined regime affects the mapping of AI-driven decision accountability to SMF holders (e.g. SMF24, SMF4).

Ingestion note

FCA publications page and the PS26/6 page were fetched directly (WebFetch). The PS26/6 page returned the underlying CP25/21 consultation content (last updated 06/01/2026, “consultation closed”), so this page is grounded in the CP25/21 proposals; the final PS26/6 rules text and exact publication date were not retrieved. Confirm against the published PS26/6 before relying on this for client deliverables.

2026-06-05 re-scan: the PS26/6 page still served CP25/21 content on direct fetch. Publication date (22 April 2026) and adopted-rule details were confirmed via WebSearch locating the PS26/6 PDF (https://www.fca.org.uk/publication/policy/ps26-6.pdf) and consistent legal commentary (Norton Rose Fulbright Global Regulation Tomorrow, CMS, Square4, Travers Smith). The PS26/6 PDF itself was not read this run — confirm clause-level detail from the PDF before client use.