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This Practice Note tracks the development of policy and guidance related to the SM&CR (and previously the SIMR), together with key dates (in bold). For more information on the SM&CR, see Practice Notes: Senior Managers and Certification Regime—essentials for SM&CR banking firms and Practical steps FCA solo-regulated firms should take to prepare for the SM&CR extension. For information on the application of the SM&CR to insurers, see Application of the SM&CR to insurers.



Benchmark firms must complete their first certification process of certification employees—BEFSA 2016, s 21 and BEFSA 2016, Sch 4 will come into force on 7 December 2021 to bring the amendments set out in the Bank of England and Financial Services Act 2016 (Commencement No 6 and Transitional Provisions) Regulations 2019, to section 63E of the Financial Services and Markets Act 2000 (FSMA 2000) (requiring the certification of employees to perform particular functions), in relation to benchmark firms, into force

7 December 2021

PRA will begin an evaluation of the effectiveness of the SM&CR and remuneration policies for banks and insurers


FCA consultation on extending the SM&CR to benchmark administrators


Deadline for FCA solo-regulated firms to submit all data on Directory Persons to the Directory by using the FCA’s Connect System

9 December 2020


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