Streamlining the Senior Managers & Certification Regime: what GPs need to know

On 15 July 2025, the Financial Conduct Authority (FCA) published Consultation Paper CP25/21, launching the first phase of reforms to the Senior Managers & Certification Regime (SMCR).

The SMCR was introduced to enhance accountability in financial services by requiring firms to assess and certify key individuals, and ensuring senior managers clearly understand their responsibilities. While the framework has improved governance, firms — including private equity and venture capital managers — have consistently raised concerns about administrative burden and duplication.

Key proposals in CP25/21

The consultation sets out targeted reforms to streamline processes while preserving accountability:

• Flexibility in senior manager approvals
  Firms will have more time to submit applications when replacing or appointing senior managers, reducing pressure during transitions.

• Reduced certification roles
  The scope of certification will be narrowed, removing some duplicative roles. This is expected to cut the number of certifications required by around 15%.

• Simplified fit-and-proper checks
  Annual checks will be clarified and streamlined, including guidance on what evidence firms must collect and how to document assessments.

• Extended deadlines for reporting
  Firms will have longer to notify the FCA of changes and update directory entries, reducing the risk of technical breaches.

• Validity of criminal record checks
  Criminal record checks will be valid for longer, avoiding unnecessary repeat requests.

What this means for GPs

For private equity and venture capital firms, these proposals could bring meaningful relief in day-to-day compliance, freeing up resources for value-adding activity. But the FCA has made it clear: accountability remains non-negotiable. Senior managers will still need to demonstrate oversight, and firms must maintain a clear audit trail.

How to prepare

1. Map your responsibilities – Identify overlapping certifications and potential duplications that could be removed.

2. Engage with the consultation – Responses are open until 7 October 2025, giving firms an opportunity to influence final rules.

3. Digitise your workflows – Automating certifications, record-keeping and directory updates will put you ahead of the curve when changes take effect.