SM&CR and approved persons regime

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This overview is a guide to the Lexis+® UK Financial Services content within the Senior Managers and Certification Regime (SM&CR) and approved persons regime (APR) subtopic, with links to the practical guidance. The materials listed cover the application of the SM&CR to banks, building societies, credit unions and Prudential Regulation Authority (PRA) designated investment firms, as well as to UK branches of non-UK firms; insurers and re-insurers; Financial Conduct Authority (FCA) solo-regulated firms, including claims management companies and benchmark administrators; and the position for appointed representatives under the Approved Persons Regime (APR).

Senior Managers and Certification Regime

The SM&CR aims to reduce harm to consumers and strengthen market integrity by improving conduct at all levels within firms and enhancing senior management accountability. The FCA and PRA consider the SM&CR to play a key role in transforming culture in the financial industry and regard it as an important supervisory tool.

Following the Parliamentary Commission on Banking Standards (PCBS) recommendations to implement a new framework for approving and holding to account certain individuals who work in the banking sector, the Financial Services (Banking Reform) Act 2013 (

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Latest Financial Services News

How Supreme Court ruling limits scope of motor finance claims

Law360, Expert analysis: On 1 August 2025, the UK Supreme Court delivered its much-anticipated judgment in the motor finance commission test cases of Johnson v FirstRand Bank Ltd, Wrench v FirstRand Bank Ltd and Hopcraft v Close Brothers Ltd [2025] UKSC 33. Tom Grodecki, Suzanne Bell and Robert Cannon, partners at Cadwalader Wickersham & Taft LLP, examine the implications of this landmark ruling while addressing the scope of motor finance claims and commission arrangements in the UK automotive finance sector. The article was prepared with contributions from fellow Cadwalader partners Sabah Nawaz and Bevis Metcalfe.

Charity director avoids prison in terrorism sanctions case

Law360, London: The director of a charity sanctioned for her ties to a pro-Hamas news outlet was given a suspended prison sentence on 13 August 2025 in the first prosecution of an individual for failing to adequately respond to a request for information by Britain's sanctions enforcer.

Financial Services—other developments (15/8/2025)

A round-up of other developments, which have not been covered in full by the LexisNexis Financial Services practical guidance team but may nevertheless be of interest.

FCA publishes multi-firm review findings of life insurers' pension transfer process

The Financial Conduct Authority (FCA) has published findings from its multi-firm review of life insurers' pension transfer process. The review, covering 18 firms managing 80% of individual personal pension policies, highlights how firms manage and monitor transfers and the challenges they face in delivering good customer outcomes. The FCA noted examples of good practice, including the use of digital platforms, improved customer communications and regular process reviews. It intends to follow up with firms where delays were identified and continues to work with industry to improve transparency, empower consumers and ensure firms meet evolving market demands.

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