First-Time Chair at a Regulated Firm: What FCA Approval Requires

The first Chair appointment at an FCA-regulated firm is a particular kind of milestone. The candidate has typically held meaningful senior roles before — often as an executive director, CEO or NED in non-regulated contexts — but is taking on the SMF9 Chair designation for the first time. The Form A application is different from a routine senior approval because the candidate cannot point to prior regulated-firm Chair experience as evidence of competence. The fitness and propriety assessment is examined more carefully, and the firm’s brief has to make the case for the candidate on the strength of transferable rather than directly comparable experience.

This guide sets out what FCA approval requires for first-time Chair appointments at regulated firms — what the assessment focuses on, what evidence the firm and candidate need to assemble, and how to manage the application process to give it the best prospect of approval. It reflects the position in November 2026, after the first phase of Senior Managers and Certification Regime (SM&CR) reforms took effect in April and while the second phase is out for consultation. For the wider context on the Chair role itself, see our SMF9 Chair hiring guide.

Why First-Time Chair Approvals Are Different

The Senior Managers and Certification Regime looks at every senior candidate through the same fitness and propriety lens. In practice, though, the assessment of a candidate’s competence and capability depends heavily on what evidence the candidate can offer. A candidate moving from a Chair role at one FCA-regulated firm to another can point to a track record of operating under the regulatory framework. A first-time Chair candidate cannot — so the firm needs to construct a different evidence base.

The FCA is explicit that this is not a bar. Its page on how it assesses senior management function applications confirms that it applies a risk-based approach, that it will consider experience gained outside financial services, and that where a candidate brings significant relevant experience from elsewhere, it will focus more on other aspects such as their understanding of the UK regulatory system. That is the space a first-time Chair application has to fill.

Three dimensions of the assessment become particularly important for first-time Chair candidates.

Transferable governance experience. The FCA wants to see that the candidate has operated at Chair-equivalent seniority in a context that demonstrates the relevant capabilities — strategic leadership of a board, working with a CEO and senior team, managing stakeholder relationships, and making sure proper governance processes are in place. Chair experience at a non-regulated firm, prior Senior Independent Director experience at a regulated firm, or comparable public sector governance experience can all support the case.

Regulatory awareness. First-time Chair candidates need to demonstrate a genuine understanding of the regulatory framework they will be operating within. The FCA does not expect first-time Chair candidates to have prior SMF approval, but it does expect them to have engaged meaningfully with the framework before applying — through professional development, mentor relationships with experienced regulated-firm Chairs, prior NED roles at regulated firms, or other relevant exposure.

Capacity to lead in the regulated context. The Chair role at a regulated firm carries specific responsibilities under the regime — leading a board that oversees the firm’s risk management framework, engagement with regulators, and leadership of board succession in a regulated context. The FCA wants evidence that the candidate has the personal capacity and willingness to take on these responsibilities, including the time commitment. A Chair who is spread across too many other boards will face questions on capacity whatever their pedigree.

None of this means first-time Chairs are second-best appointments. Many boards deliberately look beyond the small pool of sitting regulated-firm Chairs to bring in a different perspective — a former listed-company chief executive, a senior figure from a related industry, or an experienced NED stepping up. Our Chair of FCA-regulated firm recruitment work regularly involves exactly that kind of candidate. The point is simply that the case for them has to be made on paper, clearly, rather than assumed.

What the Form A Application Needs to Demonstrate

The Form A application for a first-time Chair appointment needs to address several specific points that may be taken as read for experienced candidates.

The application must set out the candidate’s full career history, with specific attention to the seniority of roles held, the size and complexity of the organisations involved, and the Chair-equivalent capabilities the candidate has demonstrated. References supporting the application typically need to speak to these specific capabilities rather than to the candidate’s general professional standing.

The application must include the firm’s Statement of Responsibilities for the Chair role, mapping the SMF9 responsibilities to what the candidate will actually own. The Statement of Responsibilities shapes the FCA’s view of what the candidate will be accountable for, which in turn shapes the competence assessment. A clear, well-constructed statement helps first-time candidates by making explicit how their transferable experience maps to the responsibilities they will assume — including any Prescribed Responsibilities allocated to the Chair, such as leading the development of the firm’s culture by the board.

The application must also address the candidate’s regulatory awareness and readiness. This typically includes any prior NED roles at regulated firms, completion of relevant professional development (such as the Institute of Directors’ Chartered Director qualification), recent engagement with the regulatory framework through committee work or advisory roles, and the candidate’s proposed approach to ongoing development in the role.

In practice, the strongest applications for first-time Chairs read as a coherent argument rather than a set of attachments. The career history, the Statement of Responsibilities, the references and the regulatory-readiness evidence should all point to the same conclusion. Where they pull in different directions — a reference that praises commercial drive while the Statement of Responsibilities emphasises oversight and challenge, for example — the assessor is left to reconcile them, and that tends to generate questions.

The Fitness and Propriety Assessment for First-Time Candidates

The FCA’s fitness and propriety standard applies to all candidates equally, but the evidence pattern differs for first-time Chair candidates.

The honesty, integrity and reputation limb is assessed on the candidate’s full career history. First-time Chair candidates with long careers in respected senior roles typically pass this limb cleanly — the same depth of senior background that supports the competence case also supports the integrity case. Anything that could be relevant — past regulatory findings, disputes, disqualification proceedings involving companies the candidate was connected with — should be disclosed and explained up front rather than left for the regulator to find.

The competence and capability limb is where first-time Chair candidates face the most scrutiny. The FCA looks for evidence that the candidate can perform the SMF9 role effectively. For experienced regulated-firm Chair candidates this evidence is direct. For first-time candidates it is necessarily based on transferable capabilities — and the application needs to construct that argument explicitly rather than rely on it being obvious.

The financial soundness limb applies routinely. First-time Chair candidates with clean personal financial backgrounds pass this limb without issue. Candidates with prior business failures, personal financial difficulty or material adverse credit history need to address these matters openly in the application.

Common Sources of Risk for First-Time Approvals

Several patterns recur in first-time Chair applications that run into problems at the assessment stage.

Generic professional history without role-specific evidence. A candidate’s CV might show meaningful senior roles, but if the application does not connect those roles specifically to the SMF9 responsibilities, the FCA may struggle to see the case for competence. The most successful first-time applications are built around the specific capabilities the SMF9 role requires, with the candidate’s career history mapped to each one explicitly.

References that speak generically rather than specifically. Senior references supporting a first-time Chair application need to speak to the capabilities the candidate has demonstrated and the contexts that translate to the regulated-firm Chair role. Generic references from senior figures, even very senior figures, carry less weight than specific references that address the relevant dimensions.

Limited recent regulatory engagement. A candidate whose engagement with regulated financial services is historic rather than recent faces more scrutiny than one whose recent professional activity shows current familiarity with the framework. First-time Chair candidates benefit from recent NED roles at regulated firms, recent advisory work in the sector, or recent professional development that demonstrates ongoing engagement.

A weak Statement of Responsibilities. If the firm’s Statement of Responsibilities is generic or unclear, the FCA cannot assess competence against it cleanly. A clear, specific statement that maps the SMF9 role to the actual board structure helps the candidate.

Inadequate engagement with the firm’s supervisor. Larger and more closely supervised firms often benefit from pre-application engagement between the firm, the candidate and the supervisory team. It is not always necessary, but it is meaningful for higher-profile appointments and complex candidate backgrounds.

Capacity and conflicts left unaddressed. First-time regulated-firm Chairs often hold a portfolio of other roles. If the application does not explain how the candidate will give the Chair role the time it needs, and how any conflicts with other directorships will be managed, the regulator is likely to ask. It is far better to answer those questions in the application than in correspondence afterwards.

How First-Time Chair Candidates Should Prepare

Several preparation steps materially improve the prospects of first-time Chair approval.

The first step is honest self-assessment well before any formal application. The candidate should review their own career history against the SMF9 responsibilities and consider where the evidence is strong and where it is thinner. Areas of weaker evidence can often be addressed through further preparation — completing relevant professional development, taking on advisory work or NED roles that build the relevant capabilities, and engaging more actively with the regulatory framework.

The IoD’s Chartered Director qualification is one of the recognised UK routes for directors who want to formalise their board capability. It is not a regulatory requirement for SMF9, but completing it signals serious investment in board practice and gives the candidate a structured framework for thinking about Chair responsibilities — useful evidence for a competence case built on transferable experience.

Prior NED roles at regulated firms — even at smaller firms or in specialist sectors — provide direct exposure to the regulatory framework and build relationships within the regulated-firm board community. Many first-time Chairs at larger regulated firms have served as NEDs at smaller regulated firms first. Board-level financial services non-executive roles are the most common stepping stone, and a period as Senior Independent Director (SMF14) can be particularly valuable because it involves working closely with a Chair and leading the Chair’s appraisal.

Recent advisory work, particularly with regulated firms or with bodies that engage with regulated firms, builds current understanding of the framework. Candidates whose recent professional activity shows active engagement with the sector face fewer questions during assessment than candidates whose engagement is historic.

Finally, candidates should prepare to talk about the regime in their own words. Whether or not an interview takes place, the Chair will need to explain the firm’s regulatory obligations to the board, challenge executives on conduct and risk, and engage with supervisors. Being able to discuss the Senior Managers Regime, the Consumer Duty where it applies, and the firm’s key regulatory risks with confidence is part of being ready for the role, not just for the application.

How Firms Should Prepare

The firm’s preparation matters as much as the candidate’s.

The brief at the start of the search should reflect the firm’s openness to first-time Chair candidates if that is genuinely the firm’s intention. A brief that says “experienced regulated-firm Chair” closes the door on first-time candidates; a brief that says “Chair-equivalent senior governance experience, with regulatory awareness sufficient to take on the SMF9 designation” opens it. The same principles apply whether the search sits within a dedicated regulated-firm mandate or a broader chairman recruitment process.

The Statement of Responsibilities for the Chair role should be drafted carefully, mapping the SMF9 responsibilities to the actual board structure and committee responsibilities. A clear statement helps the FCA assess the candidate against the right standard.

Reference preparation supports the application. The firm should work with the candidate to identify the right referees — typically people who can speak to the capabilities the SMF9 role requires rather than to the candidate’s general standing. References from board chairs, former CEOs and others with directly comparable senior governance experience carry particular weight. The firm also has its own regulatory reference obligations to meet for any candidate who has worked at another regulated firm, and these should be requested early so they do not hold up submission.

Where appropriate, the firm should engage with its supervisor before the Form A is submitted. For larger firms this engagement is often expected; for smaller firms it is optional but typically helpful. Pre-submission engagement allows the regulator to flag any concerns before the formal application begins, avoiding surprises during assessment.

Boards should also think about the composition around the new Chair. A first-time regulated-firm Chair is better supported by a board that includes NEDs with direct regulated-sector experience — an experienced Senior Independent Director (SMF14) or committee chairs who have worked under the regime. The regulator is likely to consider the strength of the board as a whole when it weighs a candidate who is new to the role.

What Happens During Assessment

The FCA assesses Form A applications against its published fitness and propriety standards and the firm’s Statement of Responsibilities. Many applications are decided on the documentation; some involve information requests where the FCA wants more clarity on specific aspects of the candidate’s background or the firm’s case for appointment. At dual-regulated firms, the PRA also assesses the application, and both regulators’ questions need answering.

The FCA says it is likely to invite candidates for interview for a small number of roles at large listed firms, and the Chair (SMF9) is one of them, alongside the CEO, chief risk officer, compliance oversight and Senior Independent Director functions. Interviews can also happen elsewhere where the risk profile warrants it. They typically focus on the candidate’s regulatory understanding, their proposed approach to the role and any aspects of their background the regulator wants to explore. Preparing for the possibility of interview — through structured rehearsal of likely topics — supports a good outcome, and is especially worthwhile for first-time Chairs.

The assessment can result in approval, approval subject to conditions or for a limited period, or refusal. Refusals at Chair level are uncommon, not least because applications that are struggling are often withdrawn before a decision, but they are possible where the candidate’s profile raises concerns that cannot be reconciled with the standard. Where conditions are imposed, they typically address a specific gap — such as training or the time the candidate gives to other roles.

Timelines and the 2026 SM&CR Reforms

Timing matters for any Chair succession, and the position has shifted during 2026. The FCA must decide on a complete senior manager application within three months of receiving it, and the clock can stop while it waits for further information or an interview. On top of that statutory period, the FCA has set itself a voluntary target of deciding at least half of SMF applications in 35 days or less, alongside a proposed statutory deadline of two months, as set out in its announcement on faster targets for authorisations. A first-time Chair application with open questions is less likely to fall into the faster half, which is another reason to get the evidence right first time. Our guide on how long FCA SMF approval takes covers planning in more detail.

In force now. The first phase of SM&CR reform — the FCA’s PS26/6 and the PRA’s PS12/26 — took effect on 24 April 2026. These changes are mainly procedural: for example, the PRA now allows firms to rely on an existing criminal record check where a current SMF holder moves to another SMF role in the same group. They do not change the substance of what a first-time Chair must demonstrate.

Proposed, not yet in force. On 22 October 2026 the FCA published CP26/37 and the PRA published CP14/26, consulting until 22 January 2027 on the second phase. The proposals would move a number of SMFs — including several committee chair and SID roles — from pre-approval to notification, remove the Certification Regime and streamline the application process. SMF9 does not appear on either regulator’s list of roles proposed for notification, so Chair appointments would still need regulatory approval. The PRA’s proposals on conditional approvals use the Chair as an example: a Chair could be required to give up non-executive directorships above a permitted maximum. Much of phase 2 depends on new legislation, and the FCA expects final rules in the first half of 2027, so boards planning a Chair change now should work to the current rules.

What This Means for Boards and Candidates

Three implications follow for boards and candidates considering first-time Chair appointments at regulated firms.

First-time Chair appointments are entirely feasible and common at regulated firms. The Chair candidate pool would be far too narrow if it required prior regulated-firm Chair experience as a precondition. The path is well established; the preparation is more involved than for experienced candidates, but outcomes are generally positive when the preparation is done.

The preparation matters more than the credential. Candidates who invest in proper preparation — relevant professional development, recent regulatory engagement and well-constructed application materials — are well placed to secure approval. Candidates who treat the application as a procedural step rather than a real assessment can face avoidable difficulties.

The brief at the firm’s end shapes the outcome. Firms that are open to first-time Chair candidates, that construct briefs accordingly, and that invest in proper application preparation widen their field and give themselves a better chance of appointing the right Chair than firms that close the door on first-time candidates by default.

Frequently asked questions

Can someone with no financial services background be approved as SMF9 Chair?

Yes. The FCA says it will consider experience gained outside financial services. The candidate must still show they understand the UK regulatory system and can lead a board that oversees a regulated business, so the application needs strong evidence of regulatory awareness.

Will a first-time Chair be interviewed by the FCA?

At large listed firms the FCA says it is likely to interview Chair candidates. At other firms an interview is possible where the regulator thinks it is needed. Either way, candidates should prepare as if one will happen.

How long does SMF9 approval take?

The statutory maximum is three months from a complete application, though the clock can stop for information requests or an interview. The FCA’s voluntary target is to decide at least half of SMF applications in 35 days or less. Complex first-time applications should be planned around the longer end.

Will the 2026 SM&CR reforms remove the need for Chair approval?

Not on current proposals. CP26/37 and CP14/26 would move several SMFs to notification, but SMF9 is not on either list. The proposals are still under consultation and are not yet in force.

Is a director qualification required?

No qualification is required for SMF9. Recognised board development, such as the IoD’s Chartered Director qualification, can strengthen the competence case for a candidate who is new to regulated-firm boards.