What is Fitness and Propriety? The FCA SMCR Guide

What is Fitness and Propriety? The FCA SMCR Guide

Fitness and propriety is the standard the Financial Conduct Authority applies to senior individuals at FCA-regulated firms. The assessment determines whether a candidate is suitable to hold a Senior Manager Function or a Certification Function under the Senior Managers and Certification Regime. A candidate who passes fitness and propriety assessment can be approved for the role; one who fails cannot. The standard sits at the centre of the regulatory framework for senior FCA-regulated firm recruitment. Smaller FCA-authorised firms often use a fractional Chief Compliance Officer to hold SMF16 a few days a month.

This guide sets out what fitness and propriety covers, how the assessment works in practice, what triggers concerns, and how candidates and firms can prepare for the process. It has been updated for the position at November 2026: the Phase 1 SMCR changes in force since 24 April 2026, the non-financial misconduct rules in force since 1 September 2026, and the Phase 2 reform proposals the FCA and PRA published in October 2026. For employers, see our Chief Compliance Officer recruitment service.

The Three Limbs of Fitness and Propriety

The FCA’s fitness and propriety framework assesses candidates against three core limbs.

Honesty, Integrity and Reputation

The first limb covers the candidate’s personal integrity and the absence of any conduct that would call their honesty into question. The assessment looks at criminal convictions, civil judgments, regulatory enforcement actions, and any other matters that bear on the candidate’s trustworthiness. The standard is high — the FCA wants senior managers at regulated firms to be individuals whose personal integrity is beyond question.

Specific matters the FCA examines include any criminal convictions (particularly involving dishonesty, financial misconduct, or violence); any FCA, PRA, or overseas regulator enforcement actions against the candidate or firms they have led; any civil judgments involving fraud or dishonesty; any directorships in firms that have entered insolvency in concerning circumstances; any disciplinary action by professional bodies; and any other matters that could damage public confidence in the regulated sector.

Two recent changes sit under this limb. Since PS26/6 took effect in April 2026, the FCA has said that adverse findings in an official investigation or public inquiry are relevant to honesty, integrity and reputation. And since 1 September 2026, the FIT guidance explains how serious non-financial misconduct, such as bullying, harassment or violence, can bear on a person’s fitness and propriety. Both points are covered in more detail below.

Competence and Capability

The second limb covers the candidate’s technical and professional competence for the specific role. The assessment looks at the candidate’s qualifications, professional experience, and demonstrated capability to discharge the responsibilities of the Senior Manager Function in question.

Specific matters the FCA examines include relevant professional qualifications (ACA, ACCA, CFA, or sector-equivalent); years of relevant experience at appropriate seniority; track record at previous senior roles; specific technical knowledge required for the role (prudential framework for bank CFOs, Solvency II for insurance CFOs, CASS for asset management); leadership experience commensurate with the role; and any patterns of poor performance or removal from previous senior roles.

Competence also includes capacity. FIT 2.2 asks whether the person has adequate time to perform the function and meet its responsibilities. That point matters most for non-executive directors with several board seats and for fractional Senior Managers who hold roles at more than one firm, and it is one of the questions the FCA most often raises on those applications.

Financial Soundness

The third limb covers the candidate’s personal financial position. The assessment looks at whether the candidate has financial difficulties that could compromise their independence of judgement or expose them to inappropriate pressure.

Specific matters the FCA examines include any personal bankruptcy proceedings or arrangements; any County Court Judgments or other adverse credit history; any material outstanding debts; any patterns of financial mismanagement; and any other circumstances that could create financial vulnerability inappropriate for a senior regulated role.

Financial soundness is not a wealth test. The FIT guidance makes clear that the FCA does not normally treat a lack of personal wealth as relevant. What matters is whether past or present financial problems suggest a risk to the person’s judgement, or a pressure that could lead them to act against the interests of the firm or its customers.

Who Is Assessed, and by Whom

Fitness and propriety applies across SMCR, but who makes the judgement, and how often, depends on where the individual sits. Boards often assume the FCA checks everyone; in practice the regulator only approves Senior Managers, and the firm carries the assessment for everyone else. The table below sets out the position under the rules in force in November 2026.

Chairs of the board and of the main board committees (SMF9 to SMF14 where they apply) are Senior Managers, so they follow the first row, not the third. For the full map of which roles fall where, see our SMF roles guide and the comparison of the Certification Regime and the Senior Managers Regime.

Payment institutions and e-money institutions sit outside SMCR. They still have to show the FCA that their directors and managers are of good repute and have the right knowledge and experience, but they do this under the Payment Services Regulations and Electronic Money Regulations, not through Form A and the Certification Regime.

When Fitness and Propriety Assessment Applies

Fitness and propriety assessment applies in three distinct contexts.

Form A approval at the start of a new SMF appointment. Every new Senior Manager Function appointment requires FCA approval through the Form A process, which includes fitness and propriety assessment. This is the most familiar context for fitness and propriety.

Annual certification by the firm. Firms must annually certify that their Certification Function holders (including many senior risk-takers, client-facing roles, and material risk takers) continue to be fit and proper. The firm makes the assessment internally rather than the FCA assessing each individual, but the standard is the same.

Ongoing reassessment when circumstances change. If a Senior Manager’s circumstances change in a way that bears on fitness and propriety — for example a criminal investigation, financial difficulty, or significant professional misconduct — the firm must reassess. The FCA may also reassess if matters come to its attention.

For firms that need a Senior Manager in post quickly, the timing of each of these steps matters. Our guide to how long FCA SMF approval takes sets out the statutory deadlines and the practical lead time, and the Form A guide for boards covers what the board has to sign off before the application goes in.

How the Assessment Works in Practice

At the Form A stage the firm submits a comprehensive application covering the candidate’s career history, qualifications, fitness and propriety attestations, and supporting documentation. The candidate completes detailed personal declarations covering criminal history, regulatory history, civil judgments, professional conduct, and financial circumstances.

The FCA reviews the application against the published fitness and propriety standards. Most applications are decided on the documentation; some involve information requests from the FCA where additional clarity is needed; a small number involve candidate interviews where the FCA has specific questions.

Decisions typically run in one of three directions. Approval — the candidate can take the role on the proposed terms. Conditional approval — the candidate can take the role subject to specific conditions (additional training, restrictions on certain activities, additional reporting). Refusal — the candidate cannot take the role.

Outright refusals are rare at senior level but possible where the candidate’s profile raises serious concerns the FCA cannot reconcile with the regulatory standard.

In practice, many applications that would struggle never reach a decision: firms withdraw them once the FCA’s questions make clear approval is unlikely. A withdrawn application still sits on the record, and the candidate will usually have to explain it on the next Form A, so the time to find a problem is before submission, not during review.

Criminal Records Checks and Regulatory References

Two pieces of evidence underpin almost every fitness and propriety assessment: the criminal records check and the regulatory reference. Both changed in 2026.

Criminal records checks

A firm applying for a Senior Manager approval must obtain a criminal records check on the candidate. Financial services roles of this kind are excepted from the usual rules under the Rehabilitation of Offenders Act 1974, so the check, and the Form A declaration, can cover convictions that would be treated as spent in other contexts. Convictions and cautions that are protected under the filtering rules do not need to be disclosed. Candidates with any history, however old, should take advice before completing the form rather than guess.

Under PS26/6, in force from 24 April 2026, a criminal records check for a new SMF application stays valid for six months, up from three. An existing Senior Manager applying for a further SMF within the same firm or group no longer needs a fresh check. Both changes reduce the risk of an application being held up because a certificate went stale while the board was finalising the offer.

For certified staff, the rules do not mandate a criminal records check, but most firms run one as part of their own certification process, and the honesty limb applies in exactly the same way.

Regulatory references under SYSC 22

The regulatory references rules in SYSC 22 require a firm appointing a Senior Manager, a certified person or a board director to request a reference from every regulated employer the candidate has worked for in the previous six years. The former employer must use the prescribed template and disclose anything it reasonably considers relevant to fitness and propriety, including Conduct Rule breaches that led to disciplinary action and any finding that the person was not fit and proper.

Three features catch firms out:

• The six-year limit does not apply to serious misconduct. Matters serious enough to be relevant to fitness and propriety can be disclosed whenever they occurred.
• References must be updated. If a former employer later learns something that would have changed a reference it gave in the last six years, it must tell the new employer.
• Timing. Following PS26/6, the FCA expects references to be provided within four weeks of a request, down from six. The same changes clarified what to disclose where an employee leaves before an investigation concludes, and how to approach overseas employers who will not give a reference in the UK format.

Since PS26/6, a Conduct Rule breach does not have to appear on a reference if the firm took no disciplinary action and considers it irrelevant to fitness and propriety. That narrows what appears on references but does not change the underlying test. For the wider process of checking senior candidates beyond the regulatory template, see our executive reference checking guide.

What Triggers Fitness and Propriety Concerns

Several patterns trigger more careful FCA scrutiny during fitness and propriety assessment.

Prior regulatory engagement at firms with subsequent issues. Candidates who have held senior roles at firms that have subsequently been subject to enforcement action, supervisory criticism, or significant operational failures face additional scrutiny. The assessment considers whether the candidate’s actions contributed to the issues or whether they were genuinely outside the candidate’s responsibility.

Departures from previous roles in concerning circumstances. Candidates who have left previous senior roles in circumstances suggesting concerns about their conduct or performance face additional scrutiny. The FCA looks at the circumstances of the departure, the firm’s view of the candidate’s conduct, and the candidate’s own account.

Adverse credit history or financial difficulty. Material adverse credit history, prior personal bankruptcy, or current financial difficulty creates concern under the financial soundness limb. The assessment considers whether the circumstances are explained, whether they have been resolved, and whether they create ongoing risk.

Limited relevant experience for the specific role. Candidates whose experience does not clearly align with the specific Senior Manager Function being applied for face additional scrutiny under the competence limb. The assessment considers whether the candidate’s background provides the technical and leadership capability the role requires.

Conduct concerns from previous firms. If previous firms have raised concerns about the candidate’s conduct through formal whistleblowing channels or in regulator engagement, this typically surfaces during the assessment and prompts additional scrutiny.

What Disqualifies a Candidate: Red Flags and Disclosure on Form A

Very little in the FIT sourcebook is an automatic bar. The FCA looks at each matter in context: how serious it was, how long ago, whether it was repeated, how the person has behaved since, and how relevant it is to the role applied for. A ten-year-old county court judgment that was paid promptly is a very different matter from an undischarged bankruptcy, and a minor motoring conviction is treated differently from a conviction for fraud.

That said, some findings make approval very unlikely in practice:

• A current FCA or PRA prohibition order, or an overseas equivalent.
• A conviction for an offence involving dishonesty, fraud or financial crime, particularly a recent one.
• Disqualification as a company director.
• A finding by a regulator, tribunal or professional body that the person acted dishonestly or lacked integrity.
• Deliberate non-disclosure, or misleading answers, on a previous application.

Other matters are red flags that need a clear explanation rather than automatic barriers: dismissal or being asked to resign from a regulated role; directorships of companies that went into insolvency; unresolved debts or recent CCJs; open regulatory or police investigations; serious non-financial misconduct findings; and unexplained gaps in employment history.

How to disclose on Form A

The fitness and propriety questions on Form A (section 5 of the current form) ask about criminal proceedings, civil proceedings, business and employment matters, and regulatory matters, both for the candidate personally and for firms they have been involved in managing. The working rule is simple: if in doubt, disclose. The FCA can only weigh a matter that has been put in front of it. A disclosed issue with a clear explanation is often approved; an issue the FCA discovers for itself raises a separate question about candour, which goes straight to the honesty and integrity limb, regardless of how minor the original matter was.

A good disclosure is factual and complete. It sets out what happened, the dates, the outcome, any supporting documents (court orders, settlement letters, discharge certificates), what the candidate has done since, and why it does not affect their suitability for this role. The firm should add its own view, showing it considered the matter and why it is still comfortable proposing the candidate.

Non-Financial Misconduct and Fitness and Propriety

Non-financial misconduct (NFM) covers behaviour such as bullying, harassment, sexual misconduct, discrimination and violence. Following consultations in 2023 and 2025, the FCA published PS25/23 on tackling non-financial misconduct in December 2025. The new rules took effect on 1 September 2026.

The policy statement does two things. It adds a Conduct Rule provision (COCON 1.1.7FR) so that serious NFM towards colleagues at non-bank firms falls within the Conduct Rules in the same way it already did for banks. And it adds guidance to FIT on how NFM should be treated in fitness and propriety assessments. The rules are not retrospective: the new Conduct Rule scope applies to behaviour from 1 September 2026.

The FIT guidance has several practical consequences for hiring:

• It counts towards honesty, integrity and reputation. Serious NFM can make a person not fit and proper, with particular weight given to violence, sexual misconduct, dishonesty and fraud, wherever they took place.
• Patterns matter. A series of smaller incidents can, taken together, raise a fitness and propriety concern even where no single incident would.
• Private life is relevant in some cases. The Conduct Rules apply to work, but conduct outside work, including on social media, can be relevant to fitness and propriety. The guidance does not require firms to monitor employees’ social media proactively.
• It surfaces on references. A finding of serious NFM that led to disciplinary action is the kind of matter that will appear on a regulatory reference and follow the person to their next regulated role.

The guidance also says that treating a colleague badly because they spoke to the regulator or used whistleblowing channels will generally breach the integrity Conduct Rule. For boards hiring senior leaders, the result is that culture and behaviour evidence now belongs in the fitness and propriety file, not just in the HR file.

How Candidates Should Prepare

Candidates can prepare for fitness and propriety assessment in several ways.

Honest self-assessment before any application. Candidates should review their own career history, regulatory engagement, financial position, and any other matters that could bear on fitness and propriety before committing to a Form A submission. Issues that surface mid-process can derail an application; issues identified early can typically be explained and managed.

Clear documentation of prior issues. Where prior issues exist — regulatory engagement, departures, financial difficulty — candidates should prepare clear, documented explanations. The FCA looks at the candidate’s account of these matters as well as the underlying facts; a clear, honest, and well-evidenced explanation typically helps the assessment.

Referees who can speak to the role-relevant capability. Strong references from credible sources — previous board chairs, CEOs, regulators where appropriate — help the competence and capability assessment. Referees should be able to speak to the specific capabilities the new role requires, not just to the candidate’s general qualities.

Up-to-date professional development. Candidates whose qualifications and continuing professional development are current and clearly documented support the competence assessment. Candidates whose qualifications are dated or whose CPD record is thin face questions about ongoing competence.

A clean, consistent record of employment. Dates on the CV, the Form A employment history and the regulatory references should match. Inconsistencies of a few months are common and harmless when explained; left unexplained, they generate questions and delay.

How Firms Should Prepare

Firms appointing senior individuals to SMF roles have their own responsibilities under the fitness and propriety framework.

The firm must conduct its own fitness and propriety due diligence before submitting Form A. This includes verifying the candidate’s qualifications, references, regulatory history, and any other matters relevant to the assessment. Search firms supporting the recruitment typically conduct initial due diligence as part of the shortlist preparation; the firm itself conducts more detailed due diligence at the offer stage.

The firm must construct the role’s Statement of Responsibility clearly and consistently with the candidate’s actual responsibilities. The Statement of Responsibility shapes the FCA’s view of what the candidate will be accountable for, which in turn shapes the competence assessment. Our note on Statements of Responsibilities best practice covers how to draft one that supports the application.

The firm should engage early with its regulatory supervisors at larger or more closely supervised firms. Some appointments benefit from pre-submission engagement with the lead supervisor to surface any concerns before formal application.

A Fitness and Propriety Checklist for Firms

The checklist below is a practical starting point for a Senior Manager or certified appointment. It is written to be copied into a firm’s own procedures and adapted. Not every check is a regulatory requirement for every population, so the Source column shows where each one comes from.

The last row is the one most often missing. A file full of checks with no recorded judgement does not show that the firm assessed anything. The FCA expects to see that someone with authority looked at the evidence, weighed any concerns, and reached a reasoned conclusion.

The Ongoing Annual Fitness and Propriety Assessment

Fitness and propriety is not a one-off gate. Under the Financial Services and Markets Act, a firm must consider at least once a year whether there are grounds on which the regulator could withdraw a Senior Manager’s approval, and certificates for certified staff last 12 months, so each certified person must be reassessed before the certificate is renewed.

A sound annual process usually includes a fresh self-declaration, refreshed credit, register and directorship searches, a review of the conduct and disciplinary record, a review of performance against the Statement of Responsibilities or role profile, and a check that training and CPD are up to date. The outcome, and the reasons for it, should be recorded.

PS26/6 made the process lighter. From 10 July 2026, firms can issue certificates digitally, can carry out recertification as part of existing processes such as annual appraisals, and can use a less detailed review where nothing has changed since the previous year. Some overlapping certifications were also removed, for example where a Senior Manager is already certified as a material risk taker at the same firm. The underlying duty to keep people under review between annual assessments has not changed: a criminal charge, a county court judgment, a serious complaint or a disciplinary finding should trigger a reassessment straight away, not wait for the next cycle.

Fitness and Propriety for Fractional and Interim SMF16 and SMF17 Holders

A large share of smaller FCA-regulated firms fill their Compliance Oversight (SMF16) and Money Laundering Reporting Officer (SMF17) roles with a fractional compliance officer who works a set number of days a month, or with an interim while a permanent hire is found. Fitness and propriety applies to these people in full. There is no lighter test because the role is part-time.

The points that come up most often on fractional and interim applications are:

• Each firm applies separately. A fractional SMF16 or SMF17 who serves three firms needs three approvals. Each firm submits its own Form A, runs its own due diligence and takes its own regulatory references. Approval at one firm does not carry across to another firm outside the group.
• Time commitment is tested. FIT 2.2 asks whether the person has enough time to do the job. Expect the FCA to ask how many days the individual spends at each firm, what their other commitments are, and how they will cover an incident at one client while working for another. A clear schedule and a written cover arrangement help.
• Conflicts must be managed. Serving firms that compete, or that have a commercial relationship, needs a documented conflicts assessment.
• Competence is judged against the specific firm. Experience as an SMF16 at a mortgage broker does not automatically show competence for an investment firm with client money; the application should map the person’s background to the firm’s actual permissions and risks.
• References multiply. Someone who has worked for several firms in six years will have several reference requests, so allow time for each.

Both SMF16 and SMF17 remain pre-approved functions under the Phase 2 proposals, so this process is not expected to change. Our SMF16 Head of Compliance recruitment and fractional MLRO pages explain how these searches run. Where a firm has lost its compliance lead without warning, the 12-week rule allows someone to cover the role while the replacement application is prepared. Since PS26/6, the 12 weeks is the deadline to submit that application rather than to get it approved, and the cover can continue while the application is decided. Our guide to an urgent SMF appointment covers that route.

What Happens if Fitness and Propriety Concerns Arise During an Existing Role

Senior managers who develop fitness and propriety concerns during their tenure face a structured process. The firm must reassess the individual against the framework. Depending on the nature and severity of the concerns, the firm may need to remove the individual from the SMF role, notify the FCA, or both.

Common triggers for in-role fitness and propriety concerns include criminal charges, civil proceedings involving dishonesty, regulatory action by other regulators, significant operational failures within the individual’s area of responsibility, or evidence of conduct concerns that come to light during the role.

The framework imposes obligations on the firm to notify the FCA promptly where material concerns arise. Failure to notify can itself constitute regulatory breach by the firm and by other Senior Managers with relevant accountability.

Since PS26/6, the FCA has also made clear that a Senior Manager who fails to take reasonable steps to make sure the firm meets its notification obligations, or that staff report matters which need notifying, could breach the Senior Manager Conduct Rules. Conduct Rule breaches now need to be notified to the FCA as such only where they lead to disciplinary action, so the quality of the firm’s disciplinary decisions has a direct effect on what the regulator sees.

The Relationship with Other Regulatory Tests

Fitness and propriety sits alongside other regulatory tests that apply to senior individuals.

The Threshold Conditions apply to the firm itself and include requirements that the firm’s management is suitable. The fitness and propriety of individual Senior Managers contributes to the firm’s overall Threshold Conditions compliance.

The Conduct Rules apply to most regulated firm employees and set standards of conduct. The Conduct Rules and fitness and propriety overlap — serious Conduct Rule breaches typically affect fitness and propriety standing.

The Senior Management Conduct Rules apply specifically to Senior Managers and include additional requirements around taking reasonable steps to ensure proper firm management. Senior Management Conduct Rule breaches affect both fitness and propriety standing and individual regulatory liability.

The Certification Regime requires firms to certify annually that Certification Function holders remain fit and proper. The certification standard mirrors the Senior Manager fitness and propriety standard but the assessment is made internally by the firm rather than externally by the FCA.

The PRA’s Fitness and Propriety Part

At dual-regulated banks, building societies, insurers and the largest investment firms, the PRA applies its own requirements alongside the FCA’s. For banks and other CRR firms, these sit in the Fitness and Propriety Part of the PRA Rulebook, with a parallel part for insurers. The PRA approves its own designated Senior Management Functions, such as the CEO, CFO, CRO and Chair, and for those roles the candidate effectively passes two fitness and propriety reviews running alongside each other. The criteria are closely aligned with FIT, but the PRA places particular weight on prudential competence and on the collective suitability of the board.

Proposed Changes: SMCR Phase 2 and the Future of Certification

On 22 October 2026, the FCA and PRA published joint proposals for the second phase of SMCR reform: FCA CP26/37 and PRA CP14/26. The consultation closes on 22 January 2027. These are proposals, not rules, and parts of them depend on the Financial Services and Markets Bill now before Parliament. Nothing below has changed yet.

The main proposals that touch fitness and propriety are:

• Removing the Certification Regime. The regulators propose dropping certification entirely: no certificates, no mandatory annual F&P certification and no certification-linked regulatory references. Firms would instead rely on the existing rules requiring them to employ honest and competent staff, assessed at hiring and whenever there is reason to reconsider. The FCA is asking whether some certification functions should be kept.
• Moving some SMFs to notification. Certain functions, including several committee chairs and SMF5 Head of Internal Audit, would become notified rather than pre-approved. The firm would assess fitness and propriety itself and notify the regulator, with automated checks only. The regulators could still require pre-approval in exceptional cases.
• Keeping pre-approval for core roles. SMF1, SMF3, SMF9, SMF16 and SMF17, among others, would stay pre-approved through Form A.
• Longer temporary cover and conditional approvals. The 12-week cover window would extend to 18 weeks, and conditional or time-limited approvals would become available in defined circumstances.

The regulators expect to publish final rules in the first half of 2027, with implementation around six months later. The practical point for firms is that fitness and propriety does not go away under any version of the proposals. Even if certification ends, firms will still have to satisfy themselves that their staff are honest and competent, and for notified Senior Managers the firm, not the regulator, would carry the whole assessment.

What This Means for Senior Recruitment

Three implications follow for boards and candidates engaged in senior FCA-regulated firm recruitment.

Fitness and propriety is part of the brief, not an afterthought. The brief at SMF level should articulate the specific fitness and propriety considerations relevant to the role. The candidate pool should be assessed against these considerations from the start, not only at the offer stage.

Search firms supporting SMF recruitment should understand the framework. A search firm that doesn’t understand fitness and propriety in detail can shortlist candidates whose backgrounds will struggle through assessment, costing the firm months. The search firm’s familiarity with the framework is part of why retained engagement at senior FCA roles is the standard.

Pre-submission due diligence prevents late-stage surprises. Firms that conduct meaningful fitness and propriety due diligence before Form A submission rarely face refusals. Firms that submit applications based on incomplete due diligence sometimes do. The investment in pre-submission due diligence is small relative to the cost of an unsuccessful application.

At Exec Capital, our compliance and risk recruitment team raises the fitness and propriety questions at the first conversation with a candidate rather than at offer, so that issues are identified, documented and discussed with the client while there is still time to deal with them.

Frequently asked questions

What does “fit and proper” mean under the FCA?

It means a person is suitable to perform a regulated role. The FCA judges this against its FIT sourcebook, looking at honesty, integrity and reputation; competence and capability; and financial soundness. The test applies to Senior Managers, certified staff and some non-executive directors.

Who decides whether someone is fit and proper?

The firm always makes the first assessment. For Senior Managers, the FCA (and the PRA for its functions) then decides whether to approve the application. For certified staff and non-SMF directors, the firm’s own judgement is final, although the regulator can challenge it.

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

Six months, following the PS26/6 changes that took effect on 24 April 2026. It was previously three months. An existing Senior Manager moving to a further SMF in the same firm or group no longer needs a new check.

Does a CCJ or past bankruptcy mean someone cannot be approved?

Not automatically. The FCA looks at the circumstances, how long ago it happened, whether it has been resolved and whether it creates any current risk. A disclosed, explained and resolved matter is often approved. Undisclosed matters cause far more difficulty.

Do spent convictions have to be disclosed on Form A?

Usually yes. These roles are excepted under the Rehabilitation of Offenders Act, so many spent convictions must be disclosed. Convictions and cautions that are protected under the filtering rules do not. Anyone unsure should take legal advice before completing the form.

How often must firms reassess fitness and propriety?

At least once a year for Senior Managers and certified staff, and immediately whenever something relevant changes, such as a criminal charge, a judgment, a disciplinary finding or a significant change of role.

Does non-financial misconduct affect fitness and propriety?

Yes. Under PS25/23, in force from 1 September 2026, serious non-financial misconduct such as bullying, harassment or violence can make a person not fit and proper, and can appear on regulatory references. A pattern of smaller incidents can also be relevant.

Can a fractional SMF16 or SMF17 be approved at more than one firm?

Yes, but each firm needs its own approval. Each submits a separate Form A, and the FCA will look closely at whether the individual has enough time and resources to perform the role properly at every firm they serve.

Is the Certification Regime being abolished?

It has been proposed, not decided. CP26/37 and PRA CP14/26 propose removing it, with consultation closing on 22 January 2027 and final rules expected in 2027. Until then, annual certification remains a legal requirement.

What happens if a Senior Manager stops being fit and proper?

The firm must reassess them, consider whether they can stay in the role, and notify the regulator. The regulator can withdraw approval and, in serious cases, make a prohibition order. The firm also has to reflect the matter on any regulatory reference it later gives.