What FCA-Regulated Firms Need to Know, Now
The regulators are listening.
In July, the FCA and PRA jointly proposed reforms to the Senior Managers & Certification Regime (SM&CR)—a regulatory cornerstone for financial services firms since 2016. For the thousands of businesses operating in the consumer credit space, the proposed changes are being positioned as a streamlining exercise, but in practice they will still demand serious attention.
And potentially – action.
Whether you’re an established lender, broker, or fintech innovator, now is the time to get ahead of the curve.
What’s Being Proposed?
The key proposals in the consultation include:
- Shorter timelines for regulatory approvals, particularly for Senior Manager Functions (SMFs)
- A simplified Certification Regime, reducing complexity around annual fitness and propriety checks
- A more targeted approach to regulatory references
- Updated guidance around the Duty of Responsibility
- A possible reframing of the Conduct Rules to ensure proportionality for smaller and solo-regulated firms
At first glance, these changes aim to reduce friction. But in practice, less complexity does not mean less responsibility.
Why This Matters for Consumer Credit Firms
Consumer credit firms, particularly those not part of large banking groups, often face unique challenges when interpreting SM&CR requirements. Some questions you need to consider:
- How do you structure SMF roles in lean organisations?
- What evidence do you need to demonstrate fitness and propriety during FCA audits?
- Are you documenting and evidencing reasonable steps as expected under the Duty of Responsibility?
These are live compliance risks and with any regulatory shift, however “simplified”, there’s an opportunity to make mistakes, miss deadlines, or misinterpret new expectations.
That’s where we come in.
How ALPH Legal & Compliance Can Help
At ALPH Legal & Compliance, we’re already working with clients across the UK to prepare for the SM&CR reforms. Here’s how we can support your business:
- Gap Analysis & SMF Structure Reviews
We assess your current governance framework against both current and proposed SM&CR expectations—highlighting risk areas, overlaps, or missing accountability lines.
- Policy Creation & Streamlining
From Certification Regime policies to Conduct Rule training guides, we ensure your internal documents are aligned, readable, and FCA-audit ready.
- Regulatory Applications & Role Changes
Need to update SMF roles or notify the FCA of changes? We’ll handle it—accurately, efficiently, and with a deep understanding of Connect and FCA process nuance.
- Ongoing Monitoring & Audit Support
Our compliance audit service will stress-test your systems against the updated regime—giving you practical insight before the regulator does.
Our Advice: Get Proactive Now!
While the consultation is open until October 2025, these changes are not theoretical. The direction of travel is clear: more proportionality, but no less scrutiny.
By acting now, firms can:
- Streamline governance processes
- Avoid late-stage compliance scrambles
- Demonstrate to the FCA that you’re forward-looking and well-prepared
Let us take the complexity out of compliance, help your business with all aspects of your regulatory requirements and support your teams with effective and compliant growth
Next Steps: Get in touch to discuss your requirements
Whether you’re preparing for an SM&CR review, applying for new permissions, or just want to sense-check your current policies, we’re here to help.
Visit: https://www.ALPHlegal.com
Book a free call: https://www.ALPHlegal.com/contact/
Give a member of our team a call: tel:01255861697
Or contact us directly at requests@ALPHlegal.com
Let’s simplify compliance without cutting corners.
ALPH Legal & Compliance Ltd – Your partners in practical, proportionate, and professional regulatory support.
ALPH Legal & Compliance can assist with all aspects of your business’ compliance needs whether that be compliance structure and policy, internal/external audit, business and regulatory change support, authorisation, supervision or just some general expert advice and guidance!
Take action now with ALPH Legal & Compliance services!
With all the regulatory shifts on the horizon, now is the time to act. Don’t wait until compliance gaps appear—engage with ALPH Legal & Compliance today to ensure your firm is ahead of the curve. Whether you need tailored guidance, compliance support, or strategic insights to drive new business, ALPH Legal & Compliance is your trusted partner in navigating FCA regulations with confidence.
Visit ALPH Legal & Compliance now and take control of your compliance future!