Chair Recruitment Timelines at FCA-Regulated Firms: A Study

Chair recruitment at FCA-regulated firms takes longer than at non-regulated equivalents. The search itself, the candidate’s notice period, the regulatory approval of the SMF9 Chair function and the depth of board engagement required all add time, and in our experience boards that plan for a Chair appointment as if it were an ordinary non-executive hire are almost always caught out. From the board’s first decision to a new Chair taking the seat, the process is usually measured in months rather than weeks, and at larger or dual-regulated firms it can run close to a year or beyond.

This guide sets out the typical phases of an SMF9 Chair appointment, what happens in each, and the variables that decide whether a particular appointment runs quickly or slowly. It draws on two things: the timescales the FCA, the PRA and HM Treasury have published for senior manager approvals, and our practitioner experience of running board-level searches for regulated firms through Chair of regulated firm recruitment. Exec Capital does not hold a statistical dataset of Chair appointment times, so we describe stages and ranges qualitatively rather than presenting precise figures. Every appointment is different, and the regulatory rules themselves changed in 2026 and are under further consultation.

The Phases of a Chair Appointment

An SMF9 Chair appointment at an FCA-regulated firm typically runs through six distinct phases. Each has its own pace, and the total timeline is the sum of the phases less whatever the board can run in parallel. The early phases are within the board’s control; the later ones depend on the candidate’s current commitments and on the regulator.

Phase 1: Board decision and brief

The board agrees to start a Chair search. Decisions at this stage include who leads the process (usually the nominations committee or the Senior Independent Director, since the outgoing Chair should not run their own succession), the budget, the choice of search firm and any external advisers. At larger regulated firms the board will often also brief its supervisor on the planned appointment, because the regulator takes a close interest in board leadership. This phase is short when the board is aligned and drags when it is not.

Phase 2: Brief construction and search firm appointment

The board appoints the search firm and finalises the brief. At SMF9 level the brief usually covers the draft Statement of Responsibilities, the firm’s strategic position, the current CEO’s working style, recent board dynamics and the type of Chair–CEO partnership the firm wants to build. It needs more detail than a non-regulated Chair brief because candidates have to judge the regulatory exposure of the role before they commit. Our SMF9 Chair hiring guide covers what a strong brief contains.

Phase 3: Candidate identification and initial engagement

The search firm maps and approaches candidates against the brief. The SMF9 pool is narrow: experienced financial services executives moving into board careers, sitting chairs with prior regulated exposure, and senior figures from the public sector or regulators moving into private sector governance. Initial conversations are normally one-to-one and confidential, and many of the strongest candidates are not actively looking, which is why this phase cannot be compressed much.

Phase 4: Interview process

The board interviews the shortlist. At Chair level this usually means several sessions with different directors – often the CEO, the Senior Independent Director, the audit and risk committee chairs and, where relevant, major shareholders. It is more involved than a C-suite process because the Chair leads the board and every director has a stake in the choice. Diary co-ordination across a full board is one of the most common sources of quiet delay.

Phase 5: Offer, references and regulator engagement

The board makes an offer, references are taken and the firm prepares its application. Referencing at Chair level goes deeper than at executive level, typically covering previous board colleagues, CEOs the candidate has worked with and, where relevant, prior regulatory engagement. Regulatory references under SMCR also have to be requested from previous regulated employers, and these do not always arrive promptly.

Phase 6: Form A submission and approval

The firm submits the application for the SMF9 function and the regulator assesses the candidate’s fitness and propriety: honesty and integrity, competence and capability, and financial soundness, together with their capacity to lead the board. At dual-regulated firms the Chair function is a PRA-designated function, so the PRA leads the assessment and the FCA’s consent is also needed. Larger firms should expect the possibility of an interview with the regulator. Our Form A approval process guide explains the paperwork in more depth.

Total Timeline by Firm Type

We do not publish week-by-week figures by firm type, because no reliable public dataset exists and individual appointments vary too much for averages to mean anything. What we can say from experience is how the pattern tends to differ between types of firm.

The phases overlap. Offer acceptance and application preparation can run together, and the candidate’s notice period usually runs alongside the approval window. The useful measure is the calendar time from the board’s decision to the Chair taking the seat, not the sum of every phase run one after another. Boards running a wider chairman recruitment process at an unregulated group company will find the regulated subsidiary sets the pace.

What Drives Variation Within the Range

Several factors decide whether a particular Chair appointment runs at the quick or slow end.

Firm complexity and supervisory intensity. The largest dual-regulated firms take longer. Assessing a Chair for a systemically important bank involves a different level of scrutiny from assessing one for a small specialist firm, and two regulators are involved.

Candidate background. Candidates who already hold, or have held, an SMF at a similar type of firm tend to move through assessment more easily than those coming into regulated financial services for the first time. A first-time Chair at an FCA-regulated firm needs more preparation, and the application has to show clearly how gaps in regulated experience are covered.

Notice period and garden leave. Sitting chairs and senior executives often have long notice periods or need to step down from other boards in an orderly way. Depending on which runs longer, the notice period or the approval, either can become the critical path.

Regulator workload. Processing times vary with application volumes. The FCA publishes quarterly operating service metrics, and periods of heavy demand, for example after major regulatory change, can stretch decisions towards the statutory limit.

Complexity of the candidate’s profile. International careers, many prior board roles or any history of regulatory engagement take longer to verify. The regulator looks at the whole professional history, and complicated histories take more time.

Concurrent vs Sequential Process Management

Boards that handle Chair appointments well run phases side by side wherever they can. Application preparation can begin while the candidate is working their notice. Regulatory references can be requested as soon as the offer is accepted. Interim cover can be agreed during the offer phase rather than once the outgoing Chair has already left.

In our experience this approach takes a meaningful amount of time out of the overall process – often the difference between a board that has its new Chair in place for the start of a financial year and one that does not. The trade-off is more management of dependencies. If the candidate’s current employer resists early disclosure, or the regulator asks for information that needs the candidate’s full attention, some steps may have to run in sequence after all.

The Form A Approval Process in Detail

Regulatory approval is usually the longest phase the board does not control, and the one most boards underestimate. It has its own structure.

Submission

The firm submits Form A covering the candidate’s career history, fitness and propriety attestations, the Statement of Responsibilities and supporting documents. Preparing a complete application takes concentrated work from the firm, the candidate and often external regulatory counsel. Time spent getting it right is well spent: the statutory clock only starts once the regulator has a complete application.

Regulator assessment

The regulator reviews the application against the fit and proper standards: honesty and integrity, competence and capability, and financial soundness. For a Chair the assessment also forms a view on whether the candidate can lead an effective board and hold the executive to account.

Information requests

Requests for further information are common and add time, depending on how much the regulator asks for and how quickly the firm and candidate respond. Some assessments include an interview with regulator staff, and the board should prepare the candidate for it.

Decision

The regulator approves, approves with conditions or a time limit, or refuses. Conditions might require training, extra reporting or support arrangements. Refusals at Chair level are uncommon, partly because weak applications are often withdrawn once concerns are raised, but they happen where a candidate’s profile raises material doubts.

What the Regulators Publish About Approval Timescales

The figures boards can rely on are the published ones. Under the Financial Services and Markets Act 2000 the regulators currently have a statutory deadline of three months to decide a complete senior manager application. In its consultation response on reforming SMCR, the government said it intends to legislate to shorten that deadline to two months, noting that the FCA and PRA already report against a two-month timeframe voluntarily.

The FCA has also set faster targets for authorisations. For senior manager applications its voluntary target is to complete at least half in 35 days, and it said it would measure its performance against the new targets from January 2026. Those are targets, not guarantees, and they apply to complete applications. A Chair application at a complex firm, or one that triggers information requests, may well take longer. Our guide to how long FCA SMF approval takes sets out what this means in practice across different functions.

How the Recent SMCR Reforms Affect Chair Timelines

Two sets of changes matter for boards planning a Chair transition.

The 12-week rule (in force since 24 April 2026). The FCA’s PS26/6 policy statement changed the rule that lets someone cover a senior manager role temporarily without approval. Firms now have 12 weeks to submit an application for the replacement, rather than 12 weeks to obtain approval, and the person providing cover can continue until the FCA determines that application. The Senior Manager Conduct Rules now apply to the person covering. Dual-regulated firms should check the PRA’s equivalent rules, since SMF9 is a PRA-designated function there.

Phase 2 proposals (published 22 October 2026). The FCA’s CP26/37 and the PRA’s CP14/26 propose moving several functions from pre-approval to notification, including the committee chairs (SMF10 to SMF13) and the Senior Independent Director (SMF14). SMF9 Chair is not on the list of functions proposed to move, so on the current proposals the board Chair would still need approval before taking up the role. The papers also propose extending the temporary cover period from 12 to 18 weeks. These are proposals: the consultations close on 22 January 2027, and boards should not plan around them until final rules are published.

The practical effect is that a gap in the Chair seat is easier to bridge than it was, but the Chair appointment itself still runs through full approval.

Common Causes of Timeline Slippage

Three patterns recur in Chair appointments that overrun.

A weak brief at the start. Searches that begin with an unclear brief produce shortlists that do not fit, which means another round of candidate identification. Time invested in the brief is nearly always recovered later in the search.

Fitness and propriety issues found late. Prior regulatory history, financial difficulty or conduct concerns lengthen assessment and can lead to refusal. Surfacing these issues before the shortlist, through candid conversations and early checks, saves a great deal of time. A search that reaches offer with a candidate carrying a material concern can fail at the approval stage and have to restart.

Board dynamics slowing the offer. A Chair appointment needs board consensus, not a single decision-maker. Searches stall when individual directors raise late objections. Boards that agree selection criteria at the outset largely avoid this.

Implications for Succession Planning

Because the overall process is long, Chair succession at a regulated firm should start well before the current Chair’s expected departure. Boards that start early can build the brief properly, get to know potential candidates over time and manage the handover calmly. Boards that start only when the Chair announces they are leaving are usually working against the clock from day one. The FCA has also made clear that the temporary cover rules are not a substitute for succession planning; its own guidance gives a retirement agreed well in advance as an example of misuse.

Interim arrangements are often needed. The Senior Independent Director can usually chair meetings for a short gap, but for a longer gap an interim chairman may be the better answer. Under the revised 12-week rule an interim Chair can cover without prior approval while the firm submits the application, but the board still has to be confident the person is fit and proper and that a credible permanent process is under way.

Chair succession is one of the few appointments the board owns rather than the CEO. Its quality depends on the board’s preparation: the brief, the candidate pipeline, early engagement with potential candidates and the handling of board dynamics during selection. That is where Exec Capital’s regulated Chair search work starts.

Frequently asked questions

How long does it take to appoint a Chair at an FCA-regulated firm?

There is no fixed figure. The search, interviews, notice period and regulatory approval together usually take many months, and larger dual-regulated firms sit at the longer end. The parts with published timescales are the regulators’ statutory deadline and the FCA’s voluntary targets.

What is the FCA’s deadline for deciding an SMF application?

The current statutory deadline is three months from receipt of a complete application. The government intends to cut it to two months, and the FCA’s voluntary target is to complete at least half of senior manager applications in 35 days.

Can someone chair the board while approval is pending?

Yes, under the temporary cover rule. Since 24 April 2026, FCA rules give firms 12 weeks to submit an application, and cover can continue until it is decided. Dual-regulated firms should check the PRA’s rules for SMF9.

Will the Chair role move to notification instead of approval?

Not under the October 2026 proposals. CP26/37 and PRA CP14/26 would move several committee chair roles and the SID to notification, but SMF9 is not among them. The proposals are still under consultation.

What most often delays a Chair appointment?

In our experience: an unclear brief, fitness and propriety issues found late, long notice periods and board disagreement at offer stage. Most can be reduced by planning early.