How SMCR is changing the senior appointment timetable for FCA-regulated firms

By Adrian Lawrence FCA, Founder, Exec Capital

Boards at FCA-regulated firms approaching senior appointments often underestimate the timetable. The substantive search work — brief, market mapping, candidate engagement, assessment, offer — proceeds on a familiar calendar. The Form A submission, fitness and propriety assessment and FCA approval process that follows offer-acceptance has its own calendar, and the two don’t slot together cleanly. The result is regulated firms expecting a senior leader to be in role within four months who discover that the realistic timeline is closer to seven or eight, and SMF function-holders carrying the role in an interim capacity for substantially longer than expected.

The pattern recurs particularly for SMF1 (CEO), SMF9 (Chair), SMF14 (SID) and SMF24 (Chief Operations Function) appointments — the senior accountability functions where the FCA exercises substantive scrutiny including, for SMF1 and SMF9 particularly, the possibility of regulator interview as part of the approval process. Firms that haven’t planned the regulatory dimension into the senior search timetable often find themselves running parallel arrangements (acting CEO, dual-hatted SMF holders) that are workable but not ideal.

The realistic timetable for senior SMF appointments

The end-to-end timetable for a senior SMF appointment at an FCA-regulated firm typically works as follows. Search phase: 10-14 weeks. Brief work, market mapping, candidate engagement and assessment, shortlist, second-round and reference work, offer.

Form A preparation phase: 2-4 weeks. The candidate prepares their Form A application with the firm and (typically) the firm’s legal advisers. This is substantive work — particularly the Statement of Responsibility, which must allocate the firm’s senior management responsibilities clearly across SMF holders, and the fit-and-proper documentation including criminal record checks, credit checks, regulatory references from previous employers, and the substantive disclosure work on any matters that could bear on the FCA’s assessment.

FCA assessment phase: 8-16 weeks (with substantial variance). The FCA reviews the application, follows up with questions to the candidate and the firm, conducts background checks, and (for higher-risk roles) may interview the candidate. The 12-week target for FCA decisions is real but holds primarily for low-friction applications; senior SMF appointments at higher-risk firms or with candidates who have any regulatory history requiring substantive treatment frequently extend beyond.

Notice period and start. Once FCA approval is granted, the candidate works any remaining notice period before joining. For senior candidates, this is often 6 months from the offer-acceptance date.

The compound effect: from search-launch to senior leader in role at an FCA-regulated firm, the realistic timetable is 26-40 weeks. Boards planning senior succession at FCA-regulated firms need to factor this in.

Practical implications for board planning

Three implications recur. First, senior succession planning at FCA-regulated firms needs longer horizons than at non-regulated firms. The Nomination Committee Chair and Board Chair work I see at strong FCA-regulated firms operates on twelve to twenty-four month forward-looking horizons for SMF appointments specifically — not because the search itself takes that long but because the substantive work pre-search and the regulatory process post-search both add material time.

Second, interim arrangements need to be planned, not improvised. Where a current SMF holder is leaving on a known date and the successor will not be approved by then, the firm needs to plan the interim coverage substantively — typically through dual-hatting an existing SMF holder or appointing a regulated interim with direct prior FCA experience. Improvised arrangements rarely sit well with the FCA.

Third, the substantive briefing of search firms needs to include the regulatory dimension. Senior search firms that don’t understand the SMCR framework substantively will calibrate their candidate pool and process accordingly — typically with predictable consequences for the regulatory phase that follows.

For our substantive treatment of SMCR senior appointments, see our SMF Roles Guide covering the full SMF framework, plus role-specific guides on SMF1 CEO, SMF9 Chair, SMF14 SID and SMF24 COO, and the broader FCA-regulated firm executive recruitment hub.