SMF20 and SMF23: The Insurance Senior Manager Functions Explained

The Senior Managers and Certification Regime applies to insurers as well as to FCA-regulated firms, but insurers have their own set of Senior Management Functions reflecting how the sector is governed. Two of the most specialist are SMF20, the Chief Actuary, and SMF23, the Chief Underwriting Officer. Both are technically demanding, credential-heavy appointments, and both carry the personal regulatory accountability that defines a Senior Management Function. This article explains what each function is, when a PRA-regulated insurer needs it, how the current SM&CR reforms affect each one, and how to approach the search.

Exec Capital runs SMF20 Chief Actuary searches and SMF23 Chief Underwriting Officer searches for insurers, reinsurers and Lloyd’s market firms as retained, research-led mandates. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate.

The Insurance SM&CR in Context

Insurers are dual-regulated: the PRA is responsible for their prudential soundness and the FCA for their conduct. The insurance SM&CR therefore includes PRA-designated functions that have no equivalent at a solo-regulated investment firm — the Chief Actuary and the Chief Underwriting Officer among them. These functions reflect the specific risks an insurer runs: the adequacy of its technical provisions and capital, and the quality of the underwriting on which its solvency ultimately rests.

The functions are set out in the Insurance – Senior Management Functions part of the PRA Rulebook. That part lists the governing functions an insurer shares with other dual-regulated firms — the Chief Executive (SMF1), Chief Finance (SMF2), Chief Risk (SMF4), Head of Internal Audit (SMF5) and the board chair roles — alongside a group that exists only in insurance: SMF20 Chief Actuary, SMF20a With-Profits Actuary, SMF23 Chief Underwriting Officer and SMF23a Underwriting Risk Oversight. Only the Chief Executive, Chief Finance and Chair of the Governing Body functions are mandatory for every firm in scope; the others apply according to what the firm does and how its senior team is organised.

Like every Senior Management Function, the insurance SMFs are held by approved persons who must be assessed as fit and proper, hold a Statement of Responsibilities, and are subject to the Conduct Rules and the Duty of Responsibility. The FCA’s Senior Managers and Certification Regime pages cover the conduct side of the regime, which applies to the same individuals. For the board-level picture at an insurer — chair, non-executives and committee chairs — see our page on insurance board appointments under SMCR.

The prudential backdrop has also changed. The Solvency UK reforms replaced the retained EU Solvency II framework with PRA rules, with the restated rules taking effect on 31 December 2024 (see PRA PS15/24). The PRA Rulebook still uses the term “UK Solvency II firm” to define scope, but the technical work a Chief Actuary owns — technical provisions, the matching adjustment, internal model governance where relevant — now sits within the Solvency UK rules.

SMF20: The Chief Actuary

SMF20 is the Chief Actuary function. The PRA Rulebook defines it as the function of having responsibility for the actuarial function that an insurer is required to maintain under the Conditions Governing Business rules. In practice it is held at Solvency UK insurers and reinsurers, and within the Lloyd’s market, by the individual with overall responsibility for the firm’s actuarial function. It is one of the most technically demanding appointments an insurer makes.

The actuarial function itself has a defined set of tasks, and the Chief Actuary is accountable for all of them:

• Technical provisions. Co-ordinating the calculation of technical provisions, assessing the methods, models and assumptions used, and judging the sufficiency and quality of the data behind them.
• Underwriting opinion. Expressing an opinion to the board on the overall underwriting policy.
• Reinsurance opinion. Expressing an opinion on the adequacy of reinsurance arrangements.
• Risk management. Contributing to the effective implementation of the risk management system, including the firm’s own risk and solvency assessment and, where the firm uses one, its internal model.

A related but distinct function, SMF20a, is the With-Profits Actuary. It applies only to firms carrying on with-profits insurance business, and its holder advises the governing body on the exercise of discretion affecting that business. It is a separate approval with its own Statement of Responsibilities, and at a life insurer with a with-profits fund the two roles are usually held by different people.

Chief Actuary candidates are typically Fellows of the Institute and Faculty of Actuaries with extensive post-qualification experience in the relevant line of business — general insurance, life, reinsurance or the firm’s specific market. The pool is defined and finite, and the strongest candidates are usually in post, which makes a research-led, confidential approach essential. Our Chief Actuary recruitment service is built around that reality.

The Chief Actuary works closely with the firm’s risk function, and SMF20 appointments frequently sit alongside a Chief Risk Officer (SMF4) search given how closely the actuarial and risk functions interlock at a regulated insurer. The Chief Actuary produces the numbers and the opinion; the Chief Risk Officer provides independent challenge of the risk profile those numbers describe. Boards that hire one without thinking about the other often end up with gaps or overlaps in responsibility.

SMF23: The Chief Underwriting Officer

SMF23 is the Chief Underwriting Officer function — a PRA Senior Management Function held by the individual with responsibility for the firm’s underwriting of general insurance business. Its scope is narrower than many people assume: the PRA Rulebook applies it only to firms that carry on general insurance business and to Lloyd’s managing agents. For an insurance company, the function covers risks borne by the firm; for a managing agent, it covers risks borne by the members of the syndicates it manages. A pure life insurer does not have an SMF23.

The Chief Underwriting Officer sets and owns the firm’s underwriting approach: risk selection, pricing discipline, portfolio management and the appetite within which the firm writes business. In practice that means owning the underwriting guidelines and authorities, the business plan by class, oversight of delegated authority arrangements, and the reporting that tells the board whether the book is performing as planned. Underwriting quality is the foundation of an insurer’s solvency, which is why the function carries Senior Management Function accountability.

A point of frequent confusion is worth clearing up: SMF23 is the Chief Underwriting Officer. There is a separate function, SMF23a, the Underwriting Risk Oversight function. Under the PRA Rulebook SMF23a applies only to the Society of Lloyd’s itself — it is the function of overseeing and influencing the underwriting plans of managing agents. The two are not interchangeable: a managing agent or general insurer appointing a Chief Underwriting Officer is appointing an SMF23 holder, while SMF23a sits at the Corporation of Lloyd’s. Getting the designation right matters for the Statement of Responsibilities and the regulatory application.

Chief Underwriting Officer candidates combine deep underwriting expertise in the relevant class of business with the leadership standing to own the function and the regulatory credibility to hold a Senior Management Function. As with the Chief Actuary, the pool is specialist and defined, and the strongest candidates are reached directly rather than through advertising. Our Chief Underwriting Officer recruitment work covers company-market insurers, reinsurers and managing agents.

SMF20a and SMF23a: The Related Functions Explained

Because the four insurance-specific designations share numbers, they are often mixed up in job titles, board papers and even draft applications. A simple way to keep them straight:

• SMF20 Chief Actuary — responsibility for the actuarial function at an insurer or reinsurer in scope of the PRA’s insurance SMF rules.
• SMF20a With-Profits Actuary — advising the governing body on discretion affecting with-profits business; only for firms that write it.
• SMF23 Chief Underwriting Officer — responsibility for underwriting at a general insurer or a Lloyd’s managing agent.
• SMF23a Underwriting Risk Oversight — oversight of managing agents’ underwriting plans; applies only to the Society of Lloyd’s.

The practical consequence for hiring is that the job title on the advert should follow the designation, not the other way round. A “Head of Underwriting” at a general insurer may or may not be the SMF23 holder depending on where overall responsibility sits, and the board needs to settle that before the search starts, not at the application stage.

When an Insurer Needs Each Function

Whether a firm needs SMF20, SMF23 or both depends on its regulatory classification, its business and the structure of its senior team. An insurer or reinsurer within the Solvency UK regime has an actuarial function and will ordinarily appoint a Chief Actuary to hold SMF20. A general insurer or managing agent writing material volumes of business will ordinarily have a Chief Underwriting Officer holding SMF23. A life insurer with a with-profits fund adds SMF20a. UK branches of overseas insurers are treated differently: the PRA rules require a Head of Third Country Branch (SMF19) but do not require the branch to have the other PRA senior management functions approved. The precise requirement is confirmed against the firm’s PRA classification at briefing.

What to look for in each appointment:

• SMF20 Chief Actuary: Fellows of the Institute and Faculty of Actuaries with post-qualification experience in the relevant class of business and command of technical provisions, reserving and capital modelling under Solvency UK;
• SMF23 Chief Underwriting Officer: senior underwriting leaders with deep class-of-business expertise, a track record of owning underwriting strategy and risk, and the standing to hold the function;
• For either: the regulatory credibility to be assessed as fit and proper for a PRA Senior Management Function;
• The judgement and temperament to discharge the Duty of Responsibility for a function on which the firm’s solvency rests.

Both functions sit within the insurer’s wider regulated leadership team, which typically includes a chief executive (SMF1), a chief finance function (SMF2), a Chief Risk Officer and, on the conduct side, compliance and financial-crime leadership. Where an insurer is also appointing those conduct functions, our SMF16 compliance oversight recruitment service covers that side of the team alongside the prudential appointments.

How the SM&CR Reforms Affect SMF20 and SMF23

The regulators are reforming the SM&CR in two phases, and both touch insurance appointments. Phase 1 is in force. The PRA’s PS12/26, published alongside the FCA’s PS26/6, took effect on 24 April 2026. The changes most relevant to an SMF20 or SMF23 hire are:

• The 12-week rule. A firm now has 12 weeks to submit a complete application for someone covering an SMF role temporarily, rather than 12 weeks to have the application determined. The regulators then have their statutory period to decide it.
• Criminal record checks. A check can be obtained up to six months before the application is submitted, rather than three, and is no longer needed where an existing SMF holder moves to another SMF role in the same group with only a short gap.
• Key function holders. Where an insurer’s key function holder is also an SMF holder — as a Chief Actuary usually is — only the SMF application is required, not a separate key function holder notification.
• Statements of Responsibilities. Updated statements and responsibilities maps are due within six months of a significant change rather than on every change.

Phase 2 is still a proposal. In October 2026 the PRA published CP14/26, consulting on deeper reforms. It proposes moving some SMFs from pre-approval to a notification regime, under which the firm would assess and notify rather than wait for regulatory approval. Proposed: SMF20 Chief Actuary and SMF20a With-Profits Actuary would become notified functions. Proposed: SMF23 Chief Underwriting Officer and SMF23a Underwriting Risk Oversight would remain pre-approved. The consultation closes on 22 January 2027, and implementation is expected in the second half of 2027, subject to the passage of the Financial Services and Markets Bill and HM Treasury’s commencement powers.

Until any final rules are made, SMF20 remains a pre-approved function and should be planned as one. Even if notification is adopted, the firm’s own fitness and propriety assessment would carry more weight, not less: the board would be signing off a Chief Actuary on its own judgement, so the quality of the search, referencing and assessment matters as much as before.

How to Run the Search

Both the Chief Actuary and Chief Underwriting Officer searches are specialist, credential-defined exercises into a finite pool. They reward a research-led, confidential approach over advertising, and a search partner who understands both the insurance market and the regulatory weight of the function. The brief should establish the firm’s Solvency UK status, its class of business and the maturity of its existing actuarial, underwriting and risk functions from the outset.

Exec Capital runs these as retained searches. Briefing covers the firm’s regulatory classification, business mix and the scope of the function; research maps qualified candidates with the relevant class-of-business and leadership experience; approach and assessment test both technical credibility and readiness to hold a Senior Management Function; and the shortlist carries assessment commentary. We support the firm through interviews, offer and the regulatory application and Statement of Responsibilities process.

A few practical points tend to decide whether these searches go smoothly:

• Settle the designation first. Confirm which SMF the role will hold, and whether any responsibilities are moving between the Chief Actuary, Chief Risk Officer and Chief Underwriting Officer.
• Plan for notice periods. Senior actuaries and underwriters are usually on long notice periods, so plan interim cover and use the 12-week rule properly where the seat will be vacant.
• Start referencing early. Regulatory references from previous employers over the past six years are part of the application, and gathering them takes time.
• Test regulatory readiness. Ask candidates to explain how they would discharge the Duty of Responsibility for the function, not only how they would run it technically.

Where the appointment sits on an authorisation, renewal or year-end timetable, our urgent SMF appointment service applies.

Frequently Asked Questions

What is the difference between SMF23 and SMF23a?

SMF23 is the Chief Underwriting Officer function, covering underwriting at a general insurer or a Lloyd’s managing agent. SMF23a is the Underwriting Risk Oversight function, which applies only to the Society of Lloyd’s and covers oversight of managing agents’ underwriting plans. A managing agent appointing a Chief Underwriting Officer is appointing an SMF23 holder.

Does every insurer need an SMF20 Chief Actuary?

The Chief Actuary function is not one of the three functions every firm must fill, but an insurer in scope of the Solvency UK regime has an actuarial function and in practice appoints a Chief Actuary to hold SMF20. Firms writing with-profits business also need the separate SMF20a With-Profits Actuary.

Does a life insurer need an SMF23?

No. Under the PRA Rulebook the Chief Underwriting Officer function applies only to firms carrying on general insurance business and to managing agents.

Will SMF20 stop needing regulatory approval?

Not yet. CP14/26 proposes moving SMF20 and SMF20a to a notification regime, but it is a consultation closing in January 2027. Until final rules are made, SMF20 needs pre-approval. SMF23 is proposed to stay pre-approved.

Can the Chief Actuary and Chief Underwriting Officer be the same person?

In practice, no — they are distinct functions requiring distinct expertise, and the Chief Actuary’s role includes giving an opinion on the underwriting policy the Chief Underwriting Officer owns. A firm needing both appoints two individuals, each approved and accountable for their own function.

Sources and Further Reading

• PRA Rulebook — Insurance: Senior Management Functions
• PRA PS12/26 — Review of the SM&CR, Phase 1
• PRA CP14/26 — Review of the SM&CR, Phase 2 (consultation)
• PRA PS15/24 — Review of Solvency II: restatement of assimilated law
• FCA — Senior Managers and Certification Regime