SM&CR: what should the insurance sector be doing to prepare?

On 26 July 2017, the FCA and PRA published three consultation papers outlining their proposals for the extension of the senior managers and certification regime (SM&CR) to all authorised firms.

The new regime, which will replace the approved persons regime, is far broader in its application and is likely to require significant change within many firms.  The extension of the SM&CR is due to be implemented in 2018, and therefore firms will need to prepare for this change in parallel with other key regulatory initiatives due for next year. The papers below set out the key elements of the regime and highlight the key activities insurers and insurance brokers should be looking to commence shortly.