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

Boards at FCA-regulated firms approaching senior appointments often underestimate the timetable. The search work itself — brief, market mapping, candidate engagement, assessment, offer — runs on a familiar calendar. The Form A submission, fitness and propriety work and regulatory approval that follow offer acceptance run on a calendar of their own, and the two do not slot together cleanly. The result is firms expecting a senior leader in role within four months who find the realistic timeline is closer to seven or eight, and existing Senior Managers carrying extra responsibilities on an interim basis for longer than anyone planned.

That timetable is now moving. On 22 April 2026 the FCA and the PRA published the first phase of their Senior Managers and Certification Regime (SM&CR) reforms, and most of the changes took effect on 24 April 2026. The 12-week rule for temporary cover has been rewritten, criminal record checks last longer, regulatory references are due faster, and the FCA has committed to quicker decisions on Senior Management Function (SMF) applications. A second phase, published for consultation on 22 October 2026, goes further. This guide explains what has changed, what has not, and how boards should now plan senior appointments — particularly SMF1 (Chief Executive), SMF9 (Chair), SMF14 (Senior Independent Director) and SMF24 (Chief Operations) roles, where the regulator’s scrutiny is heaviest and an interview with the candidate remains possible.

The realistic timetable for senior SMF appointments

The end-to-end timetable for a senior SMF appointment at an FCA-regulated firm breaks into four phases. The ranges below are planning assumptions rather than guarantees; the variance between firms and candidates is wide, and the reforms have shortened some phases more than others.

Search phase: typically 10–14 weeks. Brief, market mapping, candidate engagement and assessment, shortlist, second-round interviews, referencing and offer. For regulated roles the brief has to cover the regulatory dimension from day one: which SMF the person will hold, which prescribed responsibilities will sit with them, and whether the candidate already holds or has held an approval. A candidate who has been approved for the same function elsewhere is a different proposition, in timetable terms, from a strong executive who has never been through the process.

Form A preparation: 2–4 weeks. The candidate and the firm prepare the application, often with legal support; our Form A guide for boards covers what goes into it. This is substantive work. The Statement of Responsibilities must set out clearly what the individual will be accountable for and how that fits with the firm’s other Senior Managers. The firm has to complete its own fitness and propriety assessment, obtain a criminal record check, request regulatory references from previous employers covering the last six years, and deal properly with any disclosures that could bear on the regulator’s view. Two of the April 2026 changes help here: criminal record checks are now valid for six months before submission rather than three, and firms are expected to respond to reference requests within four weeks rather than six.

Regulatory assessment: variable. The regulator reviews the application, may raise questions with the candidate and the firm, and for higher-impact roles may interview the candidate. The statutory period for a decision on a complete application is still three months; the government has said it intends to legislate to cut that to two. Within the statutory limit, the FCA has set itself a published target of deciding at least half of SMF applications in 35 days or fewer. Straightforward applications from firms with a clean supervisory record can move quickly. Senior roles at firms the regulator considers higher risk, candidates with anything in their history that needs explaining, and incomplete or inconsistent applications still take longer — often because the clock stops while questions are answered. Our guide to how long FCA SMF approval takes sets out the variables in more detail.

Notice period and start. Once approval is granted, the candidate works out whatever notice remains with their current employer. At senior level, three to six months is common, and the clock usually starts at offer acceptance, so part of it runs in parallel with the regulatory phase. Where it does not, it adds directly to the total.

The compound effect is that, from search launch to a new senior leader in role, a realistic planning range for a senior SMF appointment is still in the region of six to nine months. The reforms take time out of the regulatory and preparation phases, and they make the interim period far easier to manage — but they do not make the overall process short, and boards planning senior succession at FCA-regulated firms need to factor that in.

What changed on 24 April 2026

The FCA’s policy statement PS26/6 and the PRA’s PS12/26 were published on 22 April 2026. Most of the changes took effect two days later; changes to forms and the revised thresholds for enhanced firms followed on 10 July 2026. The changes that matter most for the appointment timetable are these.

The 12-week rule now runs to submission, not approval

Before April, the 12-week rule allowed someone to cover an SMF role without approval for up to 12 weeks in any consecutive 12-month period when the previous holder left unexpectedly or temporarily. In practice the whole process — finding a successor, submitting the application and getting a decision — had to fit inside that window, which it often could not. Under the revised rule, the firm has 12 weeks to submit a complete application for the replacement, and the person providing cover can continue until the regulator determines it. That removes the cliff edge that used to force firms into awkward stop-gap arrangements when an approval ran late.

Criminal record checks valid for six months

A criminal record check obtained for an SMF candidate is now valid for six months before submission, up from three. For long searches, or where a preferred candidate’s start date moves, this reduces the risk of having to repeat the check. The PRA has also removed the need for a fresh check where an existing SMF holder moves to another SMF in the same group, with a gap of up to a month allowed. Firms remain responsible for fitness and propriety and can still run additional checks if they choose. Regulator systems did not recognise the longer validity period until the form changes went live on 10 July 2026.

Faster regulatory references

The FCA’s guidance now expects a firm to provide a regulatory reference within four weeks of a request, down from six; the PRA has said the FCA’s timeframe will in effect apply to all firms. The six-year look-back period is unchanged. For hiring firms, a slow reference from a former employer was a common reason for Form A delays, so the shorter expectation helps — but it is guidance rather than a hard rule, and references still need to be chased early.

Higher thresholds for enhanced firms

From 10 July 2026 the thresholds that put a solo-regulated firm into the enhanced category of the regime rose — for example, from £50bn to £65bn of assets under management, and from £35m to £45m of intermediary regulated business revenue — and will be adjusted for inflation every five years. Some firms near the old thresholds have dropped back to the core regime, which changes the number of SMFs they need to fill and the governance map behind them.

Interim cover under the revised 12-week rule

The rewritten 12-week rule is the change with the biggest practical effect on senior appointments, but it is easy to over-read. It does not let a firm leave a senior function vacant, and it does not let anyone perform an SMF indefinitely without approval. What it does is give the firm 12 weeks to identify a permanent successor and submit a complete, well-prepared application, and then keep the cover arrangement in place while the regulator reaches its decision.

Three points follow. First, 12 weeks to submit is still a short time to run a senior search and prepare a Form A. Firms that start the search when the vacancy arises, rather than when the departure is first signalled, can still run out of time. Second, the person providing cover is subject to the Senior Manager Conduct Rules while doing so, and the arrangement needs to be documented and defensible. Third, the rule is for unforeseen and temporary absences. A planned departure with a known date should be handled with a timely application, not by relying on the 12-week rule as a default.

For many firms, the right cover is an existing Senior Manager taking on the function temporarily. Where nobody internal has the capacity or the experience, an experienced interim with prior approval history is the safer option. That is particularly true for compliance oversight (SMF16) and money laundering reporting (SMF17), where gaps attract supervisory attention quickly; our guide to interim SMF16 and SMF17 cover covers the supervisory angle. When a departure is sudden, our urgent SMF appointment service focuses on getting suitable cover in place and the permanent application submitted inside the window.

Practical implications for board planning

Four implications recur. First, senior succession planning at FCA-regulated firms needs longer horizons than at unregulated firms. The strongest nomination committees we work with look 12 to 24 months ahead for SMF roles specifically — not because the search itself takes that long, but because the preparation before the search and the regulatory process after it both add material time. The April changes shorten parts of the process; they do not remove the need to plan.

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 board should decide in advance who will cover, how responsibilities will be reallocated, and how the Statement of Responsibilities and management responsibilities map will be updated. Arrangements that look improvised rarely sit well with supervisors, even when they are technically permitted.

Third, the search brief needs to include the regulatory dimension. A search firm that does not understand SM&CR will calibrate its candidate pool on commercial criteria alone, and the problems surface later, at Form A. The brief should ask whether candidates hold or have held the relevant approval, whether their regulatory references are likely to be clean, and whether anything in their history will need careful disclosure. For a chief executive, our CEO of a regulated firm recruitment service builds those questions into the first stage of assessment.

Fourth, front-load the paperwork. Start the criminal record check and reference requests as soon as a preferred candidate emerges — the six-month validity period makes this less risky than it used to be — and draft the Statement of Responsibilities alongside the offer rather than after it. A complete, consistent application is the single biggest factor in a quick decision, because incomplete applications stop the regulator’s clock.

Across our compliance and risk recruitment and wider FCA-regulated firm executive search, the firms that move fastest are those that treat the regulatory process as part of the appointment from the outset, not as a final step once the offer has been signed.

What phase 2 could change next

On 22 October 2026 the FCA published CP26/37 and the PRA published CP14/26, the second phase of the review. Both consultations close on 22 January 2027, and the FCA expects to publish final rules in the first half of 2027. Several proposals depend on legislation, and nothing in phase 2 is in force yet, but the direction is clear.

• Longer temporary cover. The PRA’s paper proposes extending the temporary cover period from 12 to 18 weeks, to be used only where there is clear justification, with firms still expected to submit applications as soon as possible.
• Some SMFs moving to notification. Both regulators propose that certain senior roles would no longer need pre-approval; firms would assess fitness and propriety themselves and notify the regulator. On the PRA side, the Chief Executive, Chief Finance and Chief Risk functions would stay pre-approved. The FCA also proposes removing some SMFs altogether.
• Removal of the Certification Regime. The government has confirmed it intends to remove the Certification Regime from the Financial Services and Markets Act 2000, with the regulators designing lighter replacement requirements in their rulebooks.
• A shorter statutory deadline. The government intends to cut the statutory period for deciding senior manager applications from three months to two.

If these proposals are adopted, the timetable for some appointments could shorten significantly — a notified role can start once the firm has done its own assessment. But accountability does not fall away: notified Senior Managers would be held to the same standards, and the firm’s own fitness and propriety work would carry more weight, not less. For the most senior roles, the pre-approval process described above will remain.

What this means for the search itself

The reforms change the regulatory calendar, but the biggest variable in most senior appointments is still the quality of the candidate’s regulatory story and the firm’s preparation. That is why our compliance and risk search work starts with each candidate’s approval history. Candidates who have held the same or a closely related SMF elsewhere, whose references will be straightforward and whose career history needs little explanation tend to move through the process faster. Strong executives without prior approval are often still the right choice, but the board should go in knowing that the assessment will be more thorough and may include an interview.

This is also where specialist knowledge of the regime earns its place. Our sister firm SMF Capital focuses solely on Senior Manager and compliance appointments, and the group’s networks are shared, so boards hiring for regulated roles get access to candidates who have already been through approval. Whatever route you take, the principle is the same: plan the regulatory process into the search from the first brief, line up the cover arrangement before you need it, and keep the application complete and consistent from the start.

Frequently asked questions

How long does the FCA have to decide an SMF application?

The statutory period is three months from receipt of a complete application. The government intends to legislate to reduce this to two months, and the FCA has published a target of deciding at least half of SMF applications in 35 days or fewer. Incomplete applications take longer because the clock stops while information is provided.

What is the 12-week rule now?

Since 24 April 2026, where an SMF holder leaves unexpectedly or is temporarily absent, a firm has 12 weeks to submit a complete application for a replacement, and the person covering can continue until the regulator decides. Previously the approval itself had to be obtained within the 12 weeks.

Is the temporary cover period being extended to 18 weeks?

It has been proposed, not adopted. The phase 2 consultations published on 22 October 2026 propose extending the period from 12 to 18 weeks where justified. The consultations close on 22 January 2027, so until final rules are published the 12-week period applies.

How long is a criminal record check valid for an SMF application?

Six months before submission, up from three. The change took effect on 24 April 2026, with regulator systems recognising it from 10 July 2026.

Is the Certification Regime being abolished?

The government has said it intends to remove it from legislation, and the regulators’ phase 2 papers set out what would replace it. Until the legislation and final rules are in place, firms must continue to certify relevant staff as now.

When should we start planning a senior SMF appointment?

As early as you can. For a planned departure, six to nine months before the expected handover is a sensible starting point, with an agreed interim cover plan in case the timetable slips.