Senior Managers & Individual Accountability (SM&CR)


On completion of this tutorial, you will be able to:

  • Understand the key failings of Approved Person Regime (APR) and the need for individual accountability and a new regime

  • Explain the three key elements of the SM&CR and understand how it impacts everyone within an organisation

  • Understand the key changes and practical implications of SM&CR

Tutorial Overview

The course reviews the previous approved persons regime and its flaws in being able to identify individual accountability in conduct failures. It looks in detail at the SM&CR which was rolled out to banks and large investment firms in 2016 and which has now been extended, in modified form, to cover implementation in all other financial services businesses.

It then explores how under the SM&CR, senior managers are approved by the regulator, employers are required to certify their own employees and regularly assess their fitness and propriety, and conduct rules are applied to all employees.

Finally, we look at how the new regime significantly increases the number of people subject to regulatory rules and enforcement, and its importance for all those working in financial services to fully understand what is expected of them.

Prerequisite Knowledge


Tutorial Level


Tutorial Duration

60 minutes