NOTE: On 15 July 2025, the government announced the Leeds Reforms, which include plans to streamline the SM&CR. At the same time, the PRA and FCA published consultation papers CP18/25 and CP25/21. The regulators propose a two-stage reform process, with Phase Two to follow pending legislative changes under HM Treasury consultation; see News Analysis: Reform of the SM&CR—Proposals and next steps. In February 2026, HMT consulted on the Appointed Representatives Regime including proposals to bring appointed representatives within the scope of the SM&CR. Comments closed on 9 April 2026. For detail, see SM&CR—one minute guide—Policy development. This Practice Note considers aspects of the Approved Persons Regime (APR), set out in the Financial Services and Markets Act (FSMA 2000), Part V, and SUP 10A in the FCA’s Handbook, which applies to appointed representatives (ARs) of Senior Manager & Certification Regime (SM&CR) Firms (defined in the decision tree in SYSC 23 Annex 1). It considers the relevant procedures related to FCA-approved persons in ARs, including applications for