How the FCA Form A approval process works: a practical guide for regulated firm boards

What Form A Is and Why It Matters

Every individual appointed to a Senior Management Function at an FCA-regulated firm must receive FCA individual pre-approval before taking up their role. That approval is requested through Form A — the standard notification form submitted via the FCA’s Connect portal. Without it, the individual cannot lawfully perform the function. There is no grace period, no informal arrangement, and no way to backdate approval once it has been granted.

Form A is not a formality. The FCA uses it to assess whether the proposed appointee meets the fit and proper threshold that the Senior Managers and Certification Regime places on every designated Senior Manager Function holder. For nomination committees and boards making SMF appointments — whether to the CEO, COO, CRO, Chair, Senior Independent Director, Head of Internal Audit, or Executive Director roles — understanding how the process works is not optional. It affects search timelines, affects how you brief candidates, and affects what information you need to collect before the appointment can proceed.

This post explains the Form A process step by step: who submits it, what the FCA looks for, how long it takes, what causes delays, and what regulated firm boards should do before they begin an SMF search.

Which Appointments Require Form A

Form A applies to any individual being appointed to a designated Senior Management Function for the first time at a particular firm, or to any individual taking up an SMF role they have not previously held at that firm. The most common SMF roles encountered in executive search are the SMF1 Chief Executive, the SMF24 Chief Operations, the SMF4 Chief Risk, the SMF3 Executive Director, the SMF9 Chair, the SMF14 Senior Independent Director, the SMF5 Head of Internal Audit, and the SMF10 through SMF13 committee chair functions.

Form A is also required when an existing employee is being promoted into an SMF role for the first time, not only when an external appointment is being made. Internal promotions are a common source of compliance errors: firms that move a senior manager into a designated function without recognising the Form A obligation create a regulatory gap that may only become apparent on supervisory review or at the point of a regulatory reference request from a future employer.

One function that operates differently is SMF2, the Chief Finance Function designation at dual-regulated firms. At banks and certain other dual-regulated businesses, the PRA is the lead regulator for the finance function, and the approval process involves the PRA rather than the FCA alone. For solo-regulated FCA firms, the finance function typically falls under the firm’s own certification framework rather than the SMF regime — and senior finance appointments at such firms are handled by our sister practice FD Capital, which specialises in that area.

Who Submits Form A — The Firm, Not the Individual

A point that frequently surprises boards encountering this process for the first time: Form A is submitted by the regulated firm, not by the proposed appointee. The individual does not apply to the FCA for their own approval. The firm makes the application on the individual’s behalf, asserting that it has assessed the candidate and determined them to be fit and proper for the function they are being appointed to perform.

This has a practical implication that shapes how boards should structure their appointment process. The firm needs to have completed its own fitness and propriety assessment — including reference checks, criminal record checks where relevant, and a review of the individual’s regulatory history — before it submits Form A. The FCA expects the firm to have done this work. It is not submitting Form A and then waiting for the FCA to tell it whether the candidate is suitable. It is certifying its own judgment, and the FCA is then conducting its own independent assessment of the same person.

The Compliance function, typically the SMF16 holder, is usually responsible for managing the Form A submission and the associated documentation. Boards commissioning an executive search for an SMF role should engage their Compliance function early — before a preferred candidate is identified, not after one has accepted an offer.

What Form A Requires

Form A is submitted through the FCA’s Connect system and requires the firm to provide comprehensive information about the proposed appointee across several categories. Understanding what is required helps boards and HR functions prepare candidates and gather documentation in parallel with the search process rather than sequentially after it.

Personal details and employment history

The form requires a complete employment history for the individual, with no unexplained gaps. Where gaps exist — career breaks, periods of self-employment, time between roles — these must be accounted for. The FCA expects the employment record to cover the individual’s full working life, not just recent roles. For senior executives with long careers, this can require piecing together historical records that are not always immediately accessible. Candidates who have worked across multiple jurisdictions, or who have had periods of portfolio work or advisory activity, should be asked to prepare a comprehensive chronology well before Form A is filed.

Fitness and propriety declarations

The individual must make a series of declarations regarding their fitness and propriety across three dimensions: honesty, integrity and reputation; competence and capability; and financial soundness. These declarations cover a wide range of matters including whether the individual has ever been subject to disciplinary action by a regulatory body, whether they have been the subject of civil or criminal proceedings, and whether they have ever been subject to a disqualification order as a company director.

The scope of the honesty and integrity declarations is broader than many candidates expect. An individual who has been the subject of a regulatory investigation — even one that did not result in formal action — should take legal advice on how to characterise that history in the declaration. The FCA’s position on non-disclosure of material information in Form A is clear: it constitutes a regulatory failure in its own right, regardless of whether the underlying matter would have been a disqualifying concern had it been properly disclosed. Boards should make clear to candidates that full, advised disclosure is in their interest.

Regulatory history and criminal records

Form A requires disclosure of criminal convictions and, depending on the jurisdiction, cautions and other formal disposals. For candidates who have worked internationally, this can require obtaining certificates of good standing or their equivalent from multiple jurisdictions. The FCA takes a global view of regulatory history: a regulatory censure from a non-UK financial services regulator is material and must be disclosed. This is an area where candidates who have worked in the US, EU, or Hong Kong regulatory environments frequently need additional preparation time — obtaining foreign criminal record checks can take several weeks.

Financial soundness

The financial soundness dimension covers personal insolvency, individual voluntary arrangements, county court judgments, and other indicators of financial difficulty. This is particularly relevant for candidates who have been directors of companies that have gone into administration or insolvency — a situation that is more common than might be expected given the number of senior executives who have worked at PE-backed or growth-stage businesses that did not survive. The question is not whether the company failed, but whether the individual’s conduct in connection with that failure raises fitness and propriety concerns.

The Regulatory Reference Requirement

Alongside Form A, the firm must obtain regulatory references from all FCA-regulated employers for whom the candidate has worked during the preceding six years. This is a mandatory requirement under FCA rules, not a discretionary check. The regulatory reference must be provided on the FCA’s standard template and must include disclosure of any conduct breaches, disciplinary actions, and whether any fitness and propriety concerns were identified during the individual’s employment.

Collecting regulatory references takes time and must be built into the appointment timeline. Former regulated employers are required to respond to regulatory reference requests, but in practice the speed and quality of response varies considerably. Firms that have experienced staff turnover in their compliance functions may struggle to locate the relevant records quickly. Some international employers may be unfamiliar with the UK regulatory reference regime and require explanation of the legal obligation to respond.

Building four to six weeks into the timeline for regulatory reference collection — before Form A is submitted — is realistic planning for most candidates. For candidates with complex international employment histories, eight weeks is safer. The regulatory reference goes back six years and covers specific conduct and fitness matters: it supplements, rather than replaces, the commercial reference process that any competent executive search firm should be conducting in parallel.

The FCA’s Assessment Process and Decision Timeline

Once Form A is submitted, the FCA has a statutory period within which to reach a decision. For most SMF appointments, the FCA aims to assess the application within three months of receiving a complete submission. In practice, straightforward appointments where the candidate has a clean regulatory history and all documentation is in order are often assessed more quickly — six to eight weeks is not uncommon for non-complex cases at smaller solo-regulated firms.

The three-month clock pauses while the FCA is waiting for additional information it has requested. If the FCA asks for further documentation or clarification, the assessment period is suspended until that information is provided. This is the most common source of extended delay in the Form A process: incomplete initial submissions that trigger information requests and effectively reset the timeline. Every piece of missing documentation at the point of submission adds weeks to the approval date.

The FCA can approve the appointment, approve with conditions (uncommon, but applied in cases where a historical matter warrants specific governance arrangements or enhanced oversight), or refuse approval. Refusals are infrequent but do occur. The regulatory implications of a refused appointment are significant for the firm — a governance gap is created at the designated function level, and the circumstances of the refusal may be relevant to the FCA’s broader supervisory assessment of the firm’s leadership quality.

When the FCA Conducts a Pre-Approval Interview

For certain SMF roles, the FCA may request an interview with the proposed appointee as part of its assessment. This is most commonly associated with the SMF9 Chair function and, in some circumstances, the SMF1 Chief Executive. An FCA pre-approval interview is more likely where:

• The firm is in an enhanced supervisory category or has recent enforcement or supervisory action in its history
• The proposed appointee has a regulatory history that warrants direct exploration rather than document review alone
• The role is being filled following a departure that attracted regulatory attention
• The firm is undergoing a significant change in its business model or regulatory permissions at the time of the appointment
• The firm is newly authorised or recently completed its initial authorisation process

Where an FCA pre-approval interview is a realistic possibility — and for Chair appointments it should always be considered a possibility — candidates should be briefed before Form A is submitted, not after. The interview is not a job interview and the FCA’s approach is not adversarial. But it does require the candidate to demonstrate a clear understanding of the accountability their Statement of Responsibilities places on them personally, and to speak credibly about how they would exercise that accountability in the context of the firm’s specific business, risk profile, and regulatory history.

A candidate who is surprised by the prospect of an FCA interview after accepting the role is in a materially weaker position than one who has been prepared for it from the outset. Boards making Chair or CEO appointments at regulated firms should treat pre-approval interview preparation as a standard part of the appointment process, not an exceptional one.

Common Causes of Delay — And How to Avoid Them

The most frequent causes of Form A delay, in order of occurrence, are:

• Incomplete employment history at submission — unexplained gaps that require follow-up correspondence with the FCA after filing
• Regulatory reference delays — slow or incomplete responses from former regulated employers, particularly those based outside the UK
• Late identification of disclosable matters — historical regulatory or legal matters that surface after initial candidate disclosure, requiring amended or supplementary submissions
• Late engagement of the Compliance function — boards that present Compliance with a confirmed appointment and an expectation of immediate filing, without having given the function time to prepare
• Documentation gaps — foreign criminal record certificates, historical employment verification for early-career periods, and professional qualification verification that takes longer to obtain than anticipated
• Candidate legal advice delays — where a candidate has a complex historical matter requiring legal review before disclosure, and this is not factored into the timeline

The single most effective action a regulated firm board can take to shorten the Form A timeline is to start the documentation gathering process as soon as a candidate enters serious consideration, not after the offer has been accepted. This requires the executive search firm, HR function, and Compliance function to work in coordination from the first shortlist stage. It is an approach that requires a different process architecture than unregulated executive searches, but it is the architecture that the regulatory framework makes necessary.

What Boards Should Do Before Starting an SMF Search

A well-prepared regulated firm approaches an SMF appointment with the following elements in place before the external search begins:

• A draft Statement of Responsibilities — Compliance should prepare a draft SoR before the search brief is finalised. The SoR defines what the incoming SMF holder will be personally accountable for, and that definition should shape the search brief rather than being drafted to fit whoever is appointed
• A briefed and resourced Compliance function — the SMF16 holder should know the search is underway and should have capacity in the workflow for Form A preparation once a preferred candidate enters the process
• A clear regulatory reference process — the firm should have decided who will send regulatory reference requests, to which former employers, using what template, and with what response deadline
• Candidate disclosure preparation material — candidates reaching the final stage should be given the Form A disclosure questions in advance, with an invitation to take legal advice on any matters that require careful characterisation
• A realistic appointment timeline — SMF appointments at FCA-regulated firms take longer than equivalent unregulated appointments. Any search-to-appointment plan that does not build in eight to twelve weeks after offer acceptance for Form A, regulatory references, and FCA assessment is not a realistic plan

Related Reading

Further reading on FCA regulated firm appointments: SMF Roles: A Complete Guide | SMF1 CEO Hiring Guide | SMF9 Chair Hiring Guide | SMF14 Senior Independent Director Guide | SMF5 Head of Internal Audit Guide | SMF24 Chief Operations Guide | SMF3 Executive Director Guide | Senior Reference Checking Guide | All FCA Recruitment Services