Hiring an SMF9 Chair: A Guide for UK Regulated Firms
SMF9 is the FCA designation that attaches personal regulatory accountability to the Chair of the Board of an FCA-regulated firm. It is a different role from a corporate Chair — and a different appointment from a Senior Independent Director, an executive director, or any of the committee chair functions under SMCR. The Chair is the most senior independent voice in the firm, holds the responsibility for the effectiveness of the Board itself, and is the principal counter-balance to the executive team. Under the regime, the Chair is also accountable to the regulator for the way the Board discharges its responsibilities — including the way the Board oversees the firm’s strategy, risk appetite, culture and conduct. Hiring into the role is one of the most consequential governance decisions a regulated firm makes.
This guide is written for nomination committees, existing chairs running succession, and CEOs and shareholders working through the appointment of a new Chair. It sets out what an SMF9 appointment actually involves: how the role differs from a corporate Chair, what the Statement of Responsibility looks like, how the FCA approval process works, how to think about the candidate pool, and how to structure the working relationship with the CEO and the rest of the Board. It draws on our work running SMF mandates across asset management, wealth management, insurance, brokerage, fintech and consumer credit firms, and on the FCA’s published guidance for solo-regulated firms operating under SMCR. For the broader SMF picture, see our SMF Roles guide; for the corresponding executive role, our SMF1 CEO hiring guide.
A Note from Our Founder — Adrian Lawrence FCA
Chair appointments under SMCR are different from Chair appointments anywhere else in UK corporate life. The candidate pool is small, the regulatory dimension shapes the offer in ways the candidate will scrutinise, and the working relationship with the CEO defines whether the firm runs well in its first year under the new Chair. Boards that approach SMF9 succession the way they would approach a corporate Chair search — relying on a relationship-led shortlist, leaving the Statement of Responsibility until late, treating FCA approval as an administrative step — consistently encounter friction. The fix is not to make the search more bureaucratic. It is to bring the regulatory and governance dimensions into the brief from the start so the candidate, the firm and the regulator are all working from the same understanding of what the role actually is.
At Exec Capital we structure SMF9 mandates around three workstreams running together: candidate identification and engagement, regulatory pathway preparation (FCA approval, fit-and-proper readiness, regulatory references), and the governance dimension (Statement of Responsibility drafting, alignment with the responsibilities map, Chair-CEO scope clarification, board composition and committee chair fit). Each affects the others. The pattern that fails most often is treating SMF9 as a pure board appointment — finding the candidate, then thinking about the regulatory and governance dimensions afterwards.
If you are running an SMF9 search now, planning Chair succession in the next 12-24 months, or weighing whether to renew an existing Chair past their typical tenure, I am happy to walk through your specific situation directly. Every SMF mandate I take on is handled personally — there are no junior account managers involved in our searches.
Speak to Adrian about your SMF9 appointment →
Adrian Lawrence FCA | Founder, Exec Capital | ICAEW Verified Fellow | ICAEW-Registered Practice | Companies House no. 13329383 | Placing senior executives and board members across UK regulated firms since 2018
What SMF9 covers
SMF9 is the Chair function under the Senior Managers and Certification Regime. It applies to the individual who chairs the Board of Directors of an FCA-regulated firm. Like SMF1, it is a prescribed senior management function that must be held by an FCA-approved individual at all times — a firm cannot operate without an SMF9 in place, and any change in the SMF9 holder triggers a regulatory notification and approval process.
The substantive scope of SMF9 covers what a corporate Chair would recognise — leadership of the Board, setting the agenda for board discussion, ensuring the Board operates effectively, managing the relationship between the Board and the executive team, succession planning at Board level, evaluating Board performance — with the regulatory dimension layered through every part of it. The SMF9 holder is personally accountable for the way the Board discharges its responsibilities, including the way it oversees the firm’s strategy, risk appetite framework, culture, and conduct outcomes.
The Chair is the principal counter-balance to the CEO. In an effective regulated firm, the Chair-CEO relationship is collaborative but not collusive — the Chair holds the executive team accountable on behalf of the Board, ensures the Board has the information and challenge it needs to exercise oversight, and intervenes where executive decisions need to be tested before they are made. The FCA’s expectations on this dimension have firmed up over the past decade, and supervisory engagement increasingly probes how the Chair has shaped the Board’s effectiveness.
One specific point worth being clear about: SMF9 is the FCA designation, not a job title. In most firms the SMF9 holder will be styled as Chair or Chairman of the Board, but in some firm structures the title used internally may differ. What matters from the regulatory perspective is who holds the SMF9 designation on the firm’s responsibilities map.
Who needs an SMF9 — and how it varies by firm classification
Every FCA-solo-regulated firm operating under SMCR needs an SMF9 in place. The basic requirement is constant; the surrounding governance environment varies by firm classification.
Core firms represent the majority of FCA-solo-regulated firms. The SMF set is more limited and the Board structure is typically smaller, but the SMF9 designation and the substantive Chair role are the same as in larger firms. Most independent asset managers, wealth managers, brokers and intermediaries fall into this category. The Chair in a Core firm often works closely with a smaller Board of perhaps four to six directors, where the relationship between the Chair, the CEO and one or two NEDs determines how effectively the firm is governed.
Enhanced firms are the largest and most complex — typically those with assets under management above £50 billion, or banking-style activities, or other features that bring them into the more demanding regime. Enhanced firms operate with formal Board committees that themselves carry SMF designations: SMF10 Chair of the Risk Committee, SMF11 Chair of the Audit Committee, SMF12 Chair of the Remuneration Committee, SMF13 Chair of the Nomination Committee. The SMF9 in an Enhanced firm operates within a more populated governance environment, working with a Senior Independent Director (SMF14) and several committee chairs whose appointments must be coordinated alongside the Chair role.
Limited Scope firms have the narrowest regime application — typically sole-trader financial advisers and certain insurance intermediaries whose regulated activity is narrow enough to warrant a reduced SMF set. The SMF9 in a Limited Scope firm may sit on a small board with limited committee structure, and the role is correspondingly broad-shouldered.
If you are not certain which classification your firm falls under, the firm’s compliance lead or external compliance adviser will know. The classification affects the search in two practical ways: which other SMFs and committee chairs need to be in place around the SMF9, and how detailed the Statement of Responsibility needs to be when the appointment is made.
What an SMF9 Chair does that a corporate Chair does not
The substantive role of any non-executive Chair includes setting the Board’s agenda, leading evaluation of the executive team, succession at Board level, and ensuring the Board has the information and time it needs to do its work. SMF9 layers regulatory accountability over all of that and adds several specific dimensions that a corporate Chair would not typically encounter.
The Chair is personally accountable to the regulator. The Chair’s Statement of Responsibility includes prescribed responsibilities allocated specifically to the Chair role — typically including responsibility for ensuring that the Board’s discussions of regulatory and conduct matters are appropriately structured and recorded, that succession planning at senior management level is effective, and that the relationship with the FCA at Board level is managed appropriately. When the FCA reviews how the firm is governed, the Chair is the individual whose accountability they look at first for the way the Board itself operates.
The relationship with the FCA is part of the role. The Chair is typically the principal point of Board-level contact with the FCA on matters that go beyond the day-to-day relationship the SMF1 manages. This includes succession discussions, governance issues, supervisory letters that require Board response, and significant regulatory events. The Chair is also expected to ensure the Board itself engages appropriately with the regulator on matters of supervisory interest. A candidate who has not held an SMF before is unlikely to have managed direct FCA engagement at this level — and the learning curve is real.
Consumer Duty oversight sits at Board level. The FCA’s Consumer Duty requires firms to deliver good outcomes for retail customers, evidenced by senior management oversight including an annual Board report on Consumer Duty outcomes. The Chair is expected to ensure the Board engages substantively with the Consumer Duty report — not just receiving it but interrogating it, challenging the executive’s framing of customer outcomes, and ensuring the Board’s response is robust. Boards that treat the Consumer Duty report as a procedural item rather than as a substantive Board discussion are increasingly visible to the FCA.
Operational resilience oversight is a Board responsibility. The FCA’s Operational Resilience policy requires firms to identify their important business services, set impact tolerances, and demonstrate they can deliver within those tolerances during severe but plausible disruption. While the day-to-day accountability sits with the executive team — typically SMF24 — the Board (and the Chair leading it) is responsible for satisfying itself that the firm’s operational resilience capability is adequate and for engaging with the FCA where it is not.
Culture is a Chair-level accountability. The FCA’s expectations on conduct culture have firmed up over the past decade, and the Chair is increasingly expected to articulate how the Board has shaped and tested the firm’s culture. This is not a soft topic in the SMCR context — culture is treated as a leading indicator of conduct outcomes, and questions about how the Chair has overseen culture in previous roles are now standard in FCA approval interviews for SMF9 appointments.
The reasonable steps test applies to the Chair as well as the executive. When something goes wrong in the firm, the FCA’s analytical question is whether the senior individuals responsible for the relevant area took reasonable steps to prevent it. For the Chair, this question typically focuses on whether the Board (under the Chair’s leadership) provided adequate oversight, whether the Chair ensured the Board had the information and challenge it needed, and whether the Chair-CEO relationship operated in a way that allowed appropriate executive challenge.
Building the SMF9 role specification
The role specification for an SMF9 search needs to communicate three things at once: the commercial and governance role, the regulatory dimension, and the working environment the candidate will join. Specifications that handle the first dimension well but skim the others systematically attract candidates who may withdraw at offer stage when they understand what the role actually entails.
The governance dimension covers the standard Chair content — leadership of the Board, agenda setting, evaluation of the executive team, Board composition and succession, committee chair appointments, Board effectiveness review. It includes the firm’s strategy and the role the Chair will play in shaping how the Board engages with strategy. It also includes the relationship with shareholders or members where applicable — particularly important in firms with PE backing or strategic investor relationships.
The regulatory dimension covers the SMF9 designation explicitly, the prescribed responsibilities allocated to the role, the firm’s classification under SMCR (Core / Enhanced / Limited Scope), the FCA supervisory category, and the regulatory priorities the firm is currently working on (Consumer Duty implementation status, operational resilience self-assessment cycle, any active FCA matters at Board level). Specifications that flag the regulatory dimension early in the brief — rather than burying it in an addendum — attract candidates who are seriously interested in the regulated dimension and screen out candidates who are not.
The Board dimension covers the existing Board composition, the SID, the committee chairs, the executive members of the Board (typically SMF1 and SMF3 holders), and the responsibilities map. SMF9 candidates evaluating an offer will want to understand the people they will be working with — particularly the CEO (with whom the working relationship is intensive), the SID (their principal independent counter-balance on the Board), and the committee chairs (whose effectiveness shapes the Board’s overall functioning). Specifications that name the surrounding senior team and describe the responsibilities map carry significantly better with experienced SMF candidates.
The strongest specifications also include a draft Statement of Responsibility — even in skeleton form. Candidates will read it carefully. The presence of a working SoR signals that the firm has done its governance homework and is approaching the search seriously rather than treating it as a relationship exercise.
The FCA approval process for SMF9
Once the firm has selected its preferred candidate, the FCA approval process begins. The mechanics are similar to SMF1 approval — and we cover the detailed mechanics in the SMF1 CEO hiring guide — but several aspects of the SMF9 approval pathway are worth flagging specifically.
The submission is built around Form A, supported by the candidate’s Statement of Responsibility, the firm’s Management Responsibilities Map, regulatory references covering the candidate’s previous six years of regulated employment, and supporting evidence on competence and capability. The FCA’s published service standard for Form A turnaround is up to three months for SMF approval, with most clean applications resolved within four to twelve weeks.
For SMF9 specifically, the FCA’s assessment focuses heavily on the candidate’s experience of Board-level governance in regulated environments, their understanding of the Chair-CEO division of responsibility, and their track record of overseeing culture and conduct outcomes. Candidates with prior SMF9 approval clear this assessment cleanly. Candidates with prior SMF14 (Senior Independent Director) experience or substantial NED experience in regulated firms typically clear it without difficulty. Candidates moving from corporate chair roles to SMF9 for the first time face a more substantive assessment, particularly if their corporate chair experience does not include comparable regulatory engagement.
Two specific points on the SMF9 approval process worth flagging:
The FCA may interview SMF9 candidates more often than other SMF candidates. The Chair role is treated as significant enough that direct engagement between the regulator and the candidate is more common than for other senior management functions. Candidates should be prepared for an interview that probes their understanding of the firm, the regime, and the specific governance challenges the firm faces.
The Chair appointment often coincides with broader board changes — a new SID, refreshed committee chairs, or a wider strategic refresh of the Board. The FCA expects the Chair to be able to articulate what the Board’s composition should look like over the next two to three years and how the appointment of the Chair fits into that broader picture. Specifications and submissions that address the Board’s wider succession plan land more credibly with the regulator than those that present the Chair appointment in isolation.
The fit-and-proper assessment for SMF9
The fit-and-proper assessment for SMF9 covers the same three statutory criteria as for any senior management function: honesty, integrity and reputation; competence and capability; and financial soundness. The application of these criteria to the Chair role has some specific dimensions worth being explicit about.
Honesty, integrity and reputation is examined in particular detail for SMF9 because the Chair role is the most visible governance position in the firm. The candidate’s regulatory history (any past regulatory action against them or against firms where they held senior or board roles), their conduct history (disciplinary outcomes, dismissals for cause, board removals), and their broader reputation in the relevant market all weigh heavily in the assessment. Candidates with anything in their record that requires explanation should expect the explanation to be probed in detail — and the firm should be ready to demonstrate why the appointment is appropriate notwithstanding.
Competence and capability for SMF9 includes both the substantive ability to chair a Board effectively and the specific knowledge of the regulatory regime under which the firm operates. The bar is high. Prior SMF9 experience is the strongest evidence. Substantial NED experience in regulated firms — particularly where the candidate has chaired Risk, Audit or Nomination Committees — is the next strongest. Candidates moving from corporate chair roles for the first time can clear competence and capability where their broader background demonstrably equips them for the role and where the firm has put in place a credible induction.
Financial soundness covers the candidate’s personal financial position. The bar is the same as for other SMF roles — anything significant must be disclosed, explainable and not indicative of broader integrity concerns.
The fit-and-proper assessment is conducted both at appointment and on an ongoing basis. The firm itself has an obligation to satisfy itself annually that the SMF9 (and other Senior Managers) remain fit and proper, and to notify the FCA promptly of any matters that could affect the assessment. Boards that treat this as a ceremonial annual exercise rather than as a substantive review can find themselves unprepared when something does come up.
The Statement of Responsibility for an SMF9 Chair
The Statement of Responsibility for the Chair sets out what the Chair is accountable for — both the prescribed responsibilities allocated to them under the regime and the broader scope of the Chair’s role. For SMF9, the SoR will typically include:
- Leadership of the Board, including ensuring the Board operates effectively as the firm’s primary oversight body
- Setting the Board’s agenda, ensuring time is allocated appropriately to strategy, risk, conduct, culture and operational matters
- Evaluating the Board’s performance on a regular cycle, typically annually with a more substantial external review every three years
- Overseeing succession at Board and Senior Manager level, including the appointment and replacement of executive directors and other Senior Managers
- Managing the Board’s relationship with the FCA, including ensuring the Board engages appropriately with supervisory communications and visits
- Allocating prescribed responsibilities across the senior management team in conjunction with the responsibilities map
The exact allocation of prescribed responsibilities varies by firm and by classification under SMCR. Some prescribed responsibilities sit by default with the Chair (responsibility for the firm’s compliance with the SMCR itself, for example), while others are typically allocated to executive senior managers. The SoR for the Chair must be consistent with how the firm’s overall responsibilities map allocates these.
Three drafting points are worth being explicit about for SMF9 SoRs.
The SoR should reflect the Chair’s non-executive nature. A Chair who is allocated prescribed responsibilities that genuinely require day-to-day operational oversight is one whose role has been miscoded. The Chair’s accountability is for ensuring those responsibilities are appropriately allocated and overseen — not for executing them personally.
Alignment with the responsibilities map is essential. The SoR cannot allocate to the Chair a responsibility that the firm’s responsibilities map shows sitting with another Senior Manager. Inconsistency between the Chair’s SoR and the map is a regulatory red flag and will surface during the FCA’s assessment.
The SoR is a working document, not a final document. Strong Chair candidates will read the draft SoR carefully and may propose amendments, particularly to clarify the Chair-CEO division of responsibility or the boundaries between the Chair and the SID. This is a healthy sign — it indicates the candidate is engaging seriously with what the role involves.
Building the candidate pool for SMF9
The SMF9 candidate pool is structurally narrow, and several factors shape who is genuinely available.
Prior SMF9 approval is the strongest signal. Candidates currently holding or recently holding SMF9 in another regulated firm carry the highest credibility with the regulator and the lowest approval risk for the hiring firm. They have demonstrated they can clear the fit-and-proper assessment, they understand the substance of the role, and they bring direct regulatory engagement experience at Board level. The challenge is that the population is small — most SMF9 holders are mid-tenure in their current role and not actively seeking a move — so discreet introduction is the standard way these searches are run.
SMF14 (Senior Independent Director) holders are a natural step-up pool. Candidates currently holding SMF14 — the SID role on the Board of another regulated firm — have lived under the regime, have an existing FCA approval, and have observed the Chair role at close range. Many SMF9 appointments come from this pool, and the step-up is well-trodden.
Experienced regulated-firm NEDs without SID experience. Candidates with substantial NED tenure in regulated firms — particularly those who have chaired Risk, Audit or Nomination Committees — can be credible SMF9 candidates without prior SID or SMF9 experience. The regulatory dimension is familiar to them, and the question becomes whether their experience of chairing committees translates into chairing the Board itself.
Corporate chairs without prior SMF approval. Strong corporate chairs from related sectors (financial services adjacent, regulated industry, large complex businesses with significant regulatory engagement) can clear the SMF9 fit-and-proper assessment with the right preparation. The most common preparation pattern is structured FCA induction, sponsorship from a current SMF holder in the firm, and a deliberately staged Statement of Responsibility that is carefully scoped during the first phase of the appointment.
One specific note on candidate availability. Chair appointments in regulated firms typically run to defined tenure — often two three-year terms, occasionally three. Candidates approaching the end of their existing term are the most genuinely available pool at any moment. Searches that connect with this rhythm — engaging candidates eighteen months before their existing term ends — see substantively better candidate availability than searches that begin only after the previous Chair has departed.
The Chair-CEO relationship
The relationship between the SMF9 Chair and the SMF1 CEO is the most important working relationship in the firm. It is also the one most likely to generate friction if it is not deliberately structured at the start of an appointment.
The healthy version of the relationship looks like this. The CEO runs the firm. The Chair leads the Board. The CEO and Chair meet regularly outside the formal Board cycle to align on strategy, on Board priorities, on emerging issues. The Chair ensures the Board has the time, information and challenge it needs to do its work; the CEO ensures the Board’s discussion is well-prepared and well-informed. When something goes wrong in the firm, the Chair tests the executive’s response on behalf of the Board; when the Board decides something, the Chair owns the relationship between the Board’s decision and the executive’s implementation.
The unhealthy version typically presents in one of two ways. The Chair gets too close to the executive — becomes part of the executive’s thinking rather than a distinct counter-balance to it. Or the Chair operates at too great a distance — Board meetings happen, decisions are made, but the Chair-CEO working relationship is thin and the Board’s challenge is therefore thin too. Both patterns are visible to the FCA over time.
For boards hiring an SMF9 Chair, the strongest specifications include explicit conversation about the Chair-CEO division of responsibility before the candidate accepts. This is partly about the candidate evaluating the role — is this a CEO they can work with, is the relationship structure sustainable — and partly about the firm setting expectations clearly. SMF9 candidates with prior experience will push for this conversation; first-time candidates may not, in which case the firm needs to lead it.
Where the existing CEO is being replaced shortly after the new Chair starts — common in turnaround or post-strategic-review situations — the candidate needs to understand this from the start. SMF9 candidates accepting a role on the assumption of CEO continuity, only to find a CEO change is being planned, often disengage early.
Tenure, succession and the Chair-NED relationship
Most regulated firms operate a Chair tenure norm of two three-year terms, with the second renewal subject to satisfactory Board review. Firms following the UK Corporate Governance Code or equivalent frameworks typically have explicit policies on Chair tenure that guide this rhythm. For SMF9 candidates evaluating a role, understanding the firm’s tenure policy and the implicit expectations on renewal is part of the offer conversation.
Succession planning at Board level — the broader programme of refreshing the NED population over time — is one of the prescribed responsibilities the Chair holds. Strong Chairs treat this as an active, ongoing responsibility rather than a periodic exercise. Specifications and offer conversations that address how the Chair is expected to handle Board succession over the coming years signal to candidates that the firm takes Board effectiveness seriously.
The Chair’s relationship with the rest of the NED population matters too. The SID (typically SMF14) is the Chair’s principal independent counter-balance — the NED who provides a route for shareholders or other directors to raise concerns outside the Chair-CEO axis. Committee chairs (SMF10 Risk, SMF11 Audit, SMF12 Remuneration, SMF13 Nomination, where applicable) are independent voices on specific dimensions of governance. The Chair’s working relationship with each of these influences how the Board operates, and SMF9 candidates with prior experience will want to understand the existing NED population before accepting the role.
Compensation, indemnity and the personal accountability dimension
SMF9 compensation in UK regulated firms operates within constraints similar to other senior management functions — and within the constraints applicable to non-executive director compensation generally. Unlike the SMF1 (where compensation is structured as executive remuneration with bonus and equity components), SMF9 compensation is typically a fixed fee paid for the Chair’s time commitment, with no performance-related variable element. This reflects the non-executive nature of the role.
Time commitment varies by firm size and complexity. A Chair role in a Core firm might involve 30-50 days per year; an Enhanced firm Chair role can run to 80-100 days. The fee level reflects the time commitment, the seniority of the role, and the firm’s classification — though the upper end of regulated-firm Chair fees is meaningfully below corporate Chair fees in equivalent listed companies.
Insurance and indemnity arrangements are an important part of the SMF9 offer. The Chair’s personal accountability under the regime means the candidate is exposed to potential FCA action against them as an individual — including fines and prohibition from regulated employment — in addition to the standard director liabilities. Most regulated firms maintain D&O insurance and SMF-specific cover; the strength of this cover is a real consideration for SMF9 candidates and should be discussed during offer rather than after acceptance.
The reasonable steps test is the dimension that experienced candidates scrutinise most carefully. SMF9 candidates will examine the firm’s risk and compliance environment, the strength of the second line, the responsibilities map, the executive team’s track record, and any matters in the firm’s recent regulatory history. They are evaluating whether the firm is one where they can take reasonable steps consistently and document their decisions appropriately. Firms that present well on this dimension attract better candidates.
Common SMF9 search pitfalls
Several patterns recur in SMF9 searches that go off-track. Each is avoidable with deliberate planning at the start.
Treating SMF9 as a relationship-led shortlist rather than a search. Boards that approach SMF9 succession by asking existing Board members to nominate candidates from their networks frequently end up with a narrow shortlist and a less rigorous selection. The candidate may be excellent — many SMF9 appointments come through this route — but the process risks weakness in the comparison. Strong searches combine network-led introductions with structured market mapping.
Drafting the Statement of Responsibility around the chosen candidate. SoRs that have been retrofitted to fit a chosen candidate tend to be weaker than SoRs built first. The retrofit version often has gaps that the FCA will probe during approval, and creates the first-year governance issue that some prescribed responsibility is unclearly allocated. The fix is to draft the SoR as part of the role specification, before the candidate is selected.
Underestimating the FCA timeline. Boards that have not factored eight to twelve weeks of FCA approval into Chair succession often end up with regulatory gaps, interim Chair arrangements, or compromises on the strongest candidate. The fix is to start the search earlier than the comfortable timeline suggests — particularly given that the most credible candidates often have current commitments that need orderly handover.
Underspecifying the Chair-CEO scope. Specifications and offers that leave the boundary between Chair and CEO scope ambiguous create first-year governance issues. The strongest appointments include explicit conversation about the Chair-CEO division of responsibility before the candidate accepts.
Skipping FCA engagement before the formal application. For Enhanced firms, or where the candidate has anything in their history that requires explanation, an informal pre-application conversation with the firm’s FCA supervisor is often valuable. It signals to the regulator that the firm is approaching the appointment seriously and provides early indication of any concerns the FCA might raise.
Treating the Chair appointment in isolation from broader Board changes. Chair appointments often coincide with refreshes elsewhere on the Board — new SID, refreshed committee chairs, executive changes. Specifications and offer conversations that address the wider Board picture land more credibly with candidates and with the regulator than those that present the Chair appointment as a standalone event.
How Exec Capital approaches SMF9 mandates
Exec Capital runs SMF9 mandates as integrated governance-and-regulatory searches. The governance dimension — Board effectiveness, Chair-CEO scope, succession planning, committee composition — receives the same rigour we bring to any board-level appointment. The regulatory dimension is built in from the brief, not added at the end. We work through the Statement of Responsibility outline with the firm, identify the candidate pool with prior SMF9 approval first and step-up candidates second, and structure the timeline around the realistic FCA approval window.
Our regulated-firm practice covers the full set of senior appointments under SMCR — SMF1 CEO, SMF3 Executive Director, SMF4 CRO, SMF24 Chief Operations Function and SMF9 Chair, alongside the senior C-suite, director-level and specialist roles that operate within regulated firms. Where the appointment falls within a sister firm’s specialism — finance and compliance functions including SMF2, SMF16 and SMF17 (FD Capital), or audit-qualified roles including SMF5 (Accountancy Capital) — we make the introduction directly and work alongside the relevant team. For the broader non-executive director landscape outside the SMF9 designation specifically, our specialist sister firm NED Capital covers wider board appointments.
For boards beginning Chair succession or refreshing how they approach previous searches, we offer a structured initial conversation that walks through the responsibilities map, the role specification and the realistic candidate pool before any formal mandate begins. For more on the broader SMF cluster, see our SMF Roles guide. For the corresponding executive role, our SMF1 CEO hiring guide sets out how we approach CEO appointments under SMCR.
Hire an SMF9 Chair with Exec Capital
Speak with Adrian Lawrence FCA today. Direct conversation, regulatory dimension built in from day one, FCA timeline planned into the search.
020 3287 9501
Further Reading and Authoritative Sources
For the FCA’s authoritative guidance on the SMCR and the SMF9 designation, see the FCA’s SMCR overview and the solo-regulated firms guidance. The FCA’s Form A guidance sets out the application requirements for SMF appointments.
For the broader regulatory framework, see the FCA’s Consumer Duty and the Operational Resilience policy, both of which create Board-level responsibilities the Chair leads on. The Bank of England Supervisory Statement on individual accountability covers the dual-regulated firm context for firms that are both FCA and PRA regulated.
For corporate governance frameworks that complement the SMCR, see the UK Corporate Governance Code published by the Financial Reporting Council, which is the foundational governance reference for listed companies and is widely used as a benchmark by regulated firms more broadly. The Institute of Directors publishes governance guidance particularly relevant to Chair effectiveness, Board evaluation, and the Chair-CEO relationship.