FCA Form A: What Boards Need to Know

FCA Form A: What Boards Need to Know When Appointing a Senior Manager

When a regulated firm appoints an individual to a Senior Management Function, the appointment cannot proceed until the FCA has formally approved the person. The mechanism for seeking that approval is the Form A application — a structured submission that initiates the FCA’s assessment of the candidate’s fitness and propriety. For boards and nomination committees who are new to regulated firm governance, or who are making their first SMF appointment at a new firm type, the Form A process is frequently misunderstood, underestimated in its timeline implications, or inadequately prepared. This guide sets out what boards need to understand before they submit.

Exec Capital works with FCA-regulated firms to place executives and non-executive directors into Senior Manager Functions through our compliance and risk recruitment practice and wider board work. We support our clients through the regulatory approval process as part of every assignment. The following is based on our direct experience of working through the Form A process across a wide range of firm types and complexity levels, checked against the FCA’s current rules and guidance as of November 2026.

What Form A Is and When It Is Required

Form A is the FCA’s application form for approval of a candidate to a Senior Management Function. Under SUP 10C of the FCA Handbook, which sets out the senior managers regime for FCA firms, a firm that wants an individual to perform a prescribed SMF must apply for and obtain approval before the individual takes up the role. The application is made online through Connect, the FCA’s submission system, which firms reach by signing in to My FCA. The form cannot be submitted retrospectively, and the individual cannot begin exercising their SMF responsibilities until approval is granted. There is no deemed approval: if three months pass without a decision, the candidate is still not approved, and the firm should chase the FCA rather than treat silence as consent. The one structured exception is temporary cover under the 12-week rule, covered later in this guide.

Form A is required for all prescribed senior management functions that apply to the firm — SMF1 (CEO), SMF2 (CFO), SMF3 (Executive Director), SMF4 (Chief Risk), SMF5 (Head of Internal Audit), SMF9 (Chair), SMF10–13 (Committee Chairs), SMF14 (Senior Independent Director), SMF16 (Compliance Oversight), SMF17 (MLRO), SMF24 (COO) and others depending on firm type. Core firms typically need only a handful of these, while enhanced and dual-regulated firms need many more. Not all designated positions require Form A — some roles are covered by the Certification Regime rather than the Senior Managers Regime — and firms should confirm with their compliance function whether a given appointment requires Form A before the search begins. Our guide to Senior Managers Regime board recruitment sets out how the SMF map shapes a board’s hiring plan.

Long Form A vs Short Form A

One of the first practical questions on any SMF appointment is which version of the form applies. The FCA operates a longer Form A and a shorter one, and choosing the right version matters because the long form asks for considerably more detail and, when submitted as a standalone SMF application, usually carries an application fee.

According to the FCA’s guidance, the long Form A applies where the candidate:

• has never held a senior management function or a controlled function;
• has not been approved to perform one for six months or more; or
• has had a change in their fitness and propriety position since they were last approved.

The short Form A is for candidates who are currently approved, or were approved within the last six months, and whose fitness and propriety position has not changed. It asks fewer questions because the regulator already holds much of the background. It does not mean a lighter assessment of the new role: the FCA will still consider whether the candidate is right for this firm, this function and this set of responsibilities.

Where an existing senior manager is moving to a different SMF within the same firm or group, the firm will normally use Form E (internal transfer), which is shorter again. For boards, the practical points are that a first-time senior manager — for example a capable deputy stepping up, or a first-time SMF1 who has never held an SMF role — will always go through the long form, will face the most questions, and should be planned for accordingly. A candidate who has been out of an approved role for more than six months, perhaps after a career break or a non-regulated position, will also be back on the long form even if they held SMFs for many years.

What the Form Requires

Form A covers several categories of information. The individual’s personal details, including full name, date of birth, addresses for the past five years, and national insurance number. Details of any regulatory history — previous applications to the FCA or another regulator, previous approvals held and their current status, and any instances where the individual has been refused, cancelled or withdrawn an application. Details of any material disclosures — criminal convictions (including spent convictions in certain circumstances), civil proceedings, bankruptcies, county court judgements, and any previous employment where the individual was dismissed or asked to resign.

The form also requires a self-certification by the individual that they are fit and proper to hold the role, supported by a statement from the firm that it has conducted its own fit and proper assessment. Our explainer on what fitness and propriety means to the FCA covers the honesty, integrity, competence and financial soundness tests in more detail. The firm must also obtain a regulatory reference from any firm for which the candidate has worked in a regulated capacity at any point in the last six years. Regulatory references are a material part of the Form A process and must be honest — firms providing references are themselves subject to FCA requirements regarding the quality and completeness of the information they provide.

The firm must carry out a criminal record check before applying. The form asks for the date of the check and any records it showed, but the certificate itself is not attached. Since 24 April 2026 a check is treated as valid for six months rather than three, and a new check is generally not needed where an existing senior manager moves to another SMF within the same firm or group. If the check is older than six months when the application goes in, the firm has to explain on the form how it is still satisfied the candidate is fit and proper. Where a candidate has lived or worked in a country where checks are not available, that must be disclosed. A long Form A will also ask for a full employment history, professional qualifications and a description of the role, and must be submitted alongside the candidate’s Statement of Responsibilities.

Regulatory References: What They Must Cover

The regulatory reference requirement is one of the most commonly underestimated aspects of the Form A process. The FCA’s SYSC 22 rules set out what regulatory references must contain — including details of any disciplinary action taken against the individual in the last six years for conduct, any information that is reasonably relevant to the FCA’s fitness and propriety assessment, and confirmation that there are no other relevant matters within the firm’s knowledge that have not been disclosed.

Regulatory references cannot be reduced to a bare confirmation of employment dates and title. A firm that provides a reference that omits relevant information — whether through oversight, commercial sensitivity, or a desire to support the individual’s career — is itself in breach of FCA rules. Candidates who have had disciplinary processes in previous roles, who have been the subject of a skilled person review, or who have had findings made against them in a supervisory context should expect those matters to appear in the regulatory reference and should discuss them with the appointing firm before the Form A is submitted.

Boards should request a draft regulatory reference from any previous employer early in the process — not at the point of Form A submission — so that there is adequate time to understand its content and, if necessary, to take advice on whether the disclosed information affects the appointment decision. Finding material disclosures at the point of Form A submission creates both regulatory timeline risk and significant governance awkwardness. The PS26/6 reforms help here: firms are now expected to supply a requested reference within four weeks rather than six. That shortens the wait but does not remove it, so the request should still go out as soon as a preferred candidate emerges. Regulatory references sit alongside, not instead of, ordinary referencing; our executive reference checking guide sets out how we approach the wider picture.

FCA Processing Times and the Approval Timeline

The FCA has a statutory period of three months from receiving an application in which to reach a decision on a Form A. In January 2026 it also began measuring itself against a faster voluntary target: it aims to decide at least half of senior manager applications in no more than 35 days, and has said it supports reducing the statutory deadline to two months. That shorter statutory period is a proposal and should not be relied on for planning until it is in force. In practice, straightforward applications for well-established regulated firm types can be processed well within the statutory period. Complex applications — those involving material disclosures, regulatory history at other firms, or a first-time appointment at a firm the FCA has limited supervisory familiarity with — can take the full three months or longer if the FCA asks for further information.

When the FCA asks for further information or arranges an interview, it stops the clock until the information arrives or the interview has taken place. The statutory period therefore measures the FCA’s own handling time, not elapsed calendar time. An application that generates two information requests in succession can take considerably longer than three months from submission to decision, even though the FCA has stayed within its statutory period. The FCA also warns that slow responses to its questions can lead to an application being rejected. Boards should plan for a realistic best-case timeline of about six weeks and a contingency timeline of four to five months for the full Form A process from submission to approval. Our separate guide on how long FCA SMF approval takes goes into this in more depth.

At firms that are dual-regulated by the FCA and PRA, both regulators are involved in the approval: the PRA leads on PRA-designated functions with FCA consent, and the FCA leads on its own functions. The PRA typically takes a more intensive approach for CEO, CFO and CRO appointments at banks and insurers, and the parallel FCA/PRA process can add time and complexity to the overall approval timeline. The PRA’s companion policy statement to PS26/6 is PS12/26, and dual-regulated firms need to read the two together. Exec Capital’s experience across dual-regulated appointments is that the combined process realistically takes four to six months from brief to approved appointee in post.

Step-by-Step Form A Timeline

The table below sets out the stages a typical SMF appointment goes through, from deciding the role is needed to the approved senior manager starting. Durations are indicative ranges from our own experience, apart from the FCA’s statutory period and service target, which are taken from FCA publications. Every appointment differs, and the FCA’s stages depend heavily on the quality of what it receives.

The stages most within the board’s control are three and four. Most of the avoidable delay we see comes from starting reference requests late, submitting before the Statement of Responsibilities is settled, or sending a pack that leaves an obvious question unanswered.

The FCA Regulatory Interview

For senior appointments at complex or higher-risk firms, the FCA may request a regulatory interview with the proposed SMF holder as part of the approval process. This is more common for CEO and chair appointments at large listed firms, and for senior roles at banks, insurers and larger investment managers, than at smaller or lower-complexity firms, but it can be requested at any firm type where the FCA has questions about the individual’s fitness, competence or understanding of the role. The FCA’s page on how it processes applications explains that interviews are held by a small panel, usually including authorisations and supervision staff, either at the regulator’s offices or remotely, and that the firm is told in advance which areas the panel will explore.

The regulatory interview is not a formality. It is a genuine assessment of whether the individual understands the regulatory obligations of the role, has a credible plan for managing their SMF responsibilities, and presents as someone with whom the FCA can have a constructive supervisory relationship. Candidates who are unprepared for the level of regulatory fluency the FCA expects — who cannot articulate the firm’s key risks, the regulatory framework that applies to its activities, or their own approach to managing their accountability under the Statement of Responsibilities — risk leaving a negative impression that affects the regulatory relationship from the outset. The FCA can invite a candidate back for a second interview, or ask a fresh panel for an independent view, so a weak first interview is not always fatal, but it adds time.

Exec Capital provides interview preparation support as part of our regulatory firm search process. We work with candidates and boards to ensure the individual is fully briefed on the FCA’s expectations and on the firm’s regulatory profile before any supervisory interaction takes place.

Practical Steps for Boards Before Submitting Form A

Several steps taken before the Form A submission will reduce the risk of delays and improve the quality of the outcome. First, instruct the firm’s compliance function or legal advisers to confirm the specific SMF designation that applies to the role and any firm-specific regulatory history that may be material context for the FCA’s assessment. Second, request a draft regulatory reference from all relevant previous employers as early as the point at which a preferred candidate is identified — not after the offer has been made and accepted. Third, brief the candidate on the material disclosure requirements so that any potentially disclosable matters are identified and discussed before, rather than during, the formal process.

Fourth, prepare the Statement of Responsibilities carefully before the Form A is submitted — the SoR is a live document from the point of submission and should accurately reflect the individual’s actual scope of accountability. Our guide to Statements of Responsibilities for board appointments covers how to draft one that matches the job. Fifth, ensure the individual understands that their personal information submitted as part of the Form A application will be shared with the FCA and may be used in subsequent supervisory or enforcement contexts.

Sixth, agree who owns the application inside the firm and who will answer FCA questions quickly once it is submitted. Finally, remember that the application must stay accurate while it is pending: if anything in it changes before the FCA decides — a new role elsewhere, a change in the scope of responsibilities, a newly identified disclosure — the firm should tell the FCA straight away rather than wait to be asked.

What Goes Wrong: Common Reasons for Delay or Withdrawal

The FCA’s own guidance and our experience point to a short list of recurring problems. None of them is unusual, and most are avoidable with earlier preparation.

• Checks not finished before applying. The FCA names incomplete criminal record checks and missing regulatory references as a common cause of delay. Submitting early to “get in the queue” usually costs time rather than saving it.
• Disclosures that are thin or late. A county court judgment, an old dismissal or a regulatory finding that is mentioned without explanation invites questions. Setting out the facts and why the firm is still satisfied is far better than leaving the FCA to find them.
• A vague Statement of Responsibilities. Responsibilities that do not match the job title, overlap with another senior manager or leave a prescribed responsibility unallocated tend to come back with questions.
• Competence gaps for the specific firm. A strong candidate from a different sector may still need to show how their experience fits this firm’s products, customers and risks.
• Unrealistic time commitment. Particularly for part-time and fractional holders, and for candidates with several other roles, the FCA will want to see that the hours are credible.
• Slow answers to FCA questions. The clock stops while the FCA waits, and the FCA has said slow responses can lead to an application being rejected.

Where it becomes clear an application is unlikely to succeed, the firm can withdraw it at any time before a decision, using Form B through Connect. The FCA’s guidance says both the firm and the candidate must consent. If the candidate wants the assessment to continue, the FCA may carry on without the firm’s support. A refusal leads to statutory notices and a published record, which is why a candid conversation between the board, the candidate and advisers is usually better than letting a weak application run to a formal decision. Boards should also keep in mind that a withdrawn application is part of the candidate’s regulatory history and will have to be disclosed on future applications.

Form A for a Fractional or Part-Time SMF16 or SMF17

A large share of the SMF approvals we see are for part-time holders of SMF16 (compliance oversight) and SMF17 (money laundering reporting), or both roles combined in one person, at smaller firms such as brokers, payment and e-money firms, consumer credit firms and IFAs. The FCA approves the individual for the function, not for a number of days, so a fractional holder goes through the same Form A as a full-time one. What changes is the evidence the firm needs to give about time and capacity.

In our experience the questions an FCA case officer is most likely to explore on a part-time application are these: how many days or hours a week the individual will give the firm; what other roles they hold, including other SMFs and directorships; how they will be reachable when something goes wrong outside their contracted days; who supports them day to day; and whether the time allocated is proportionate to the firm’s size, customer base and risk profile. A firm that answers those questions in the application, rather than waiting for them, tends to have a smoother process.

• Set out the commitment. State the agreed days per week or month and how that was arrived at, for example from the compliance monitoring plan, the volume of suspicious activity reports or the number of appointed representatives.
• List other roles honestly. Give every other SMF, directorship and consultancy, with the time each takes. The total must look manageable.
• Show the support around them. Name the in-house staff, systems and escalation routes that keep the function running between visits.
• Explain availability. Describe how the individual can be reached for urgent matters, such as a suspicious activity report that cannot wait for their next day in the office.
• Reflect it in the contract and SoR. The engagement letter, the Statement of Responsibilities and the Form A should all describe the same role and the same time commitment.

Our fractional compliance officer and fractional MLRO services place experienced SMF16 and SMF17 holders on this basis, and our SMF16 Head of Compliance hiring guide covers what to look for in the candidate. If you are deciding whether one person should hold both functions, that decision should be made, and justified, before the Form A goes in.

When the Firm Cannot Wait for Approval: Temporary SMF Cover

Where a regulated firm faces an SMF vacancy that cannot wait for the full Form A approval process — an unplanned departure, a regulatory remediation requirement, or an operational necessity — the FCA Handbook allows temporary SMF cover under what is known as the 12-week rule. The rule changed on 24 April 2026 under PS26/6. Previously, the 12 weeks was the period within which cover had to end or approval be obtained. It is now a deadline for submitting the application: if a valid and complete application for the permanent holder is made within 12 weeks, the temporary cover can continue until the FCA decides. The person providing cover is subject to the Senior Manager Conduct Rules while they do so, and the FCA expects firms to use the flexibility reasonably and infrequently, alongside proper succession planning. Firms should take legal and compliance advice on whether their specific circumstances meet the conditions for temporary cover and what notification obligations apply.

Exec Capital can provide access to experienced interim candidates who have previously held SMF designations and who understand the regulatory obligations associated with temporary appointments. Interim coverage while the permanent Form A process progresses is frequently the most commercially sensible approach to an SMF vacancy. Our page on urgent SMF appointments explains how we handle short-notice cover, and our guide to interim SMF16 and SMF17 cover looks at what the FCA expects while it is in place.

What Could Change Next: the CP26/37 Proposals

In October 2026 the FCA published CP26/37, the second phase of its review of the senior managers and certification regime, alongside the PRA’s CP14/26. The consultation runs to 22 January 2027. For Form A, the most relevant proposals are:

• Notification instead of approval for some SMFs. For dual-regulated and enhanced firms, the FCA proposes that SMF5 (Head of Internal Audit) and SMF10 to SMF15 (committee chairs and the Senior Independent Director) would be notified rather than pre-approved. The PRA proposes a similar shift for a large share of its own functions.
• Fewer functions. SMF18 (Other Overall Responsibility) and SMF22 (Local Responsibility) would be removed, with responsibilities reallocated.
• Longer temporary cover window. The deadline for submitting an application or notification for cover during an absence would extend from 12 to 18 weeks.
• Changes to certification. The paper also proposes significant changes to the Certification Regime.

These are proposals, not rules. Until final rules are published, firms should run every SMF appointment on the current Form A basis. Roles that matter most for smaller firms — SMF1, SMF3, SMF9, SMF16 and SMF17 — are not among those proposed to move to notification, so the advice in this guide will continue to apply to them.

Working with Exec Capital on Regulated Firm Appointments

Exec Capital integrates the Form A approval timeline into every search at an FCA-regulated firm from the point of the initial brief. We advise on how to structure the search process to minimise the risk of Form A delays, support regulatory reference collection during the appointment process, and provide briefing support to candidates and boards ahead of any FCA regulatory interview. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate. To discuss a senior manager appointment, see our compliance and risk recruitment service or call 0203 834 9616.

Frequently asked questions

What is an FCA Form A?

FCA Form A is the application a regulated firm submits to the FCA, through Connect, to have an individual approved to perform a Senior Management Function such as CEO, Chair, Head of Compliance or MLRO. The firm makes the application and must have assessed the candidate as fit and proper before it does.

What is the FCA long Form A?

The long Form A is the fuller version of the application. It applies where the candidate has never held an SMF or controlled function, has not been approved for one in the last six months, or has had a change in their fitness and propriety position since last approved. The short Form A is for candidates whose approval is current or recent and unchanged.

How long does FCA Form A approval take?

The FCA must decide within three months of receiving the application, and aims to decide at least half of senior manager applications in no more than 35 days. Requests for further information and interviews stop the clock, so complex applications can take longer in calendar terms.

Can a senior manager start before Form A is approved?

Not in the SMF role itself. A firm can use the 12-week rule to have someone provide temporary cover, and since April 2026 that cover can continue until the FCA decides as long as a valid, complete application is submitted within 12 weeks.

How long is a criminal record check valid for a Form A?

Since 24 April 2026, six months. If the check is older when the application is submitted, the firm must explain on the form why it is still satisfied the candidate is fit and proper.

Does a fractional SMF16 or SMF17 need a full Form A?

Yes. The FCA approves the person for the function, not for a set number of days. The firm should explain the time commitment, the individual’s other roles and the support around them so the FCA can see the arrangement is workable.

Can a Form A application be withdrawn?

Yes, at any time before the FCA decides, using Form B through Connect. The FCA’s guidance says both the firm and the candidate must consent, and the withdrawal becomes part of the candidate’s regulatory history.