The Directory—a public register of key individuals working in financial services
The Directory—a public register of key individuals working in financial services

The following Financial Services guidance note provides comprehensive and up to date legal information covering:

  • The Directory—a public register of key individuals working in financial services
  • Overview of the Directory
  • The Financial Services Register
  • The Directory: purpose
  • The Directory: statutory framework, rules and guidance
  • Directory Persons
  • Information published on the Directory
  • Practicalities—information reporting, transitional provisions and time frames
  • Where firms fail to submit information or submit inaccurate information

Overview of the Directory

As a consequence of the extension of the Senior Managers & Certification Regime (SM&CR) to solo-regulated firms in December 2019, the Financial Services Register (FS Register), the regulators’ record of authorised persons, is limited to information on regulated firms and Senior Management Function (SMF) holders. This is a significant change from the Approved Persons Regime under which the FCA approved, and maintaind a register of, a greater population of the financial services workforce. (From December 2019, the application of the APR is limited to appointed representatives and benchmark administrators that do not undertake regulated activities). In response to its proposals to extend the SM&CR, the FCA received ‘substantial feedback’ on the value of maintaining one central public record with information on SMF holders, and other key individuals in regulated firms who will no longer appear on the FS Register, such as those holding SM&CR Certification Functions and those who undertake business with clients and require a qualification to do so. The FCA therefore introduced the Directory—a public register to provide a central location for information on Senior Managers and other key individuals, known as ‘Directory Persons’, at all FSMA-authorised firms across multiple sectors regulated by the FCA. This Practice Note provides an overview of the Directory and the practical steps firms must take to