PRA and FCA propose simplifying accountability regime, cutting number of roles facing checks

UK financial regulators want to significantly reduce the number of financial services roles that face enhanced checks. The Prudential Regulation Authority (PRA, part of the Bank of England) and the Financial Conduct Authority (FCA) announced parallel consultations on 22 October 2026 on simplifying the Senior Managers and Certification Regime (SM&CR).

What is the SM&CR

The regime was introduced 10 years ago to build a culture of accountability among senior decision-makers in regulated firms. According to the regulators, the proposed changes would remove unnecessary burdens, while high standards of individual accountability and conduct would stay unchanged. The changes are expected to save firms around £2 billion over 10 years.

Key proposals

• Removing regulator pre-approval for some functions, including Chief Actuaries and Chairs of Risk and Audit Committees. Firms would only notify regulators of such appointments, but would remain responsible for ensuring candidates are fit and proper.
• Scrapping the Certification Regime, meaning annual certification checks, for about 139,000 people below senior manager level. They would also no longer need to appear on the Financial Services Register.
• Raising the threshold for reporting conduct rule breaches for most staff below senior manager level and streamlining conduct rule training.

Some roles, such as CEOs, CFOs and Chairs, will still require regulator pre-approval, including a fit and proper assessment. In high-risk cases, regulators will be able to require pre-approval for roles that are otherwise only notified.

Impact on firms and timeline

The PRA estimates the reforms will cut pre-approvals under its regime by 43% and halve the overall burden. For some FCA-regulated firms, around 15% of applications would move to notification and two senior manager roles would be removed, saving a further 19%.

The consultations run until 22 January, and the regulators expect to publish policy in 2027. Some reforms require changes in legislation, so once it is passed the PRA and FCA want to implement them quickly. The changes were announced in speeches at Mansion House. Katharine Braddick of the PRA also presented a five-year strategy for the PRA there.

Braddick said the proposals keep checks on the most important roles while reducing administrative burden that is not needed. Sarah Pritchard of the FCA said the same impact can be achieved with a more streamlined regime.

What this means for you

The changes mainly affect people employed by regulated financial firms, such as banks, insurers and investment firms. If the proposals take effect, some staff below senior manager level would no longer be subject to annual certification. For now, though, this is only a proposal under consultation, and final rules are expected in 2027 at the earliest.