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. 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.

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 10A of the FCA Handbook, any firm that appoints an individual to a prescribed SMF must submit a complete Form A before the individual takes up the role. The form cannot be submitted retrospectively and the individual cannot begin exercising their SMF responsibilities until approval is granted — or until the FCA confirms that approval has been granted, or until three months have elapsed without a decision and the firm considers approval to have been given by default.

Form A is required for all prescribed senior management functions — 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. 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.

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. The firm must also provide 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 submission and must be honest — firms providing references are themselves subject to FCA requirements regarding the quality and completeness of the information they provide.

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.

FCA Processing Times and the Approval Timeline

The FCA has a statutory period of three months in which to reach a decision on a Form A application. In practice, straightforward applications for well-established regulated firm types are often processed within four to eight weeks. 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 issues a request for further information that temporarily pauses the statutory clock.

The three-month period restarts from the date of any further information request. If the FCA receives incomplete information and must seek clarification, the clock pauses until the firm responds. An application that generates two information requests in succession can therefore take five to seven months in total, even if no individual period exceeds three months. Boards should plan for a realistic best-case timeline of six weeks and a contingency timeline of four to five months for the full Form A process from submission to approval.

At firms that are dual-regulated by the FCA and PRA, both regulators must approve the Form A appointment. 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. 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.

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 CFO appointments 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 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.

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. 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.

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 — there are mechanisms under the FCA Handbook for temporary SMF cover. The rules governing temporary appointments under SUP 10A allow firms to appoint an individual on a temporary basis without prior approval in certain circumstances, subject to notification to the FCA and a time limit. Firms should take legal and compliance advice on whether their specific circumstances meet the requirements for temporary cover and what the notification obligations entail.

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.

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 regulated firm search is led personally by Adrian Lawrence FCA on 0203 834 9616.