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SM&CR phase 2: Most significant reform consultation since regime began

Direct low angle view of historical City of London coat of arms crest mounted on decorative blue cast iron bridge light post in daylight.
Photo: Getty Images

Billy Bradley, CMS; Hannah Manning, CMS

13 min read

Includes removal of the Certification Regime and Directory, moving SMFs from pre-approval, and reducing firms in the Enhanced regime.

On October 22, 2026, the FCA and Prudential Regulation Authority (PRA) (together, the Regulators) published their long-awaited Phase 2 consultations on reform of the Senior Managers and Certification Regime (SM&CR): FCA CP26/37 (the FCA Consultation Paper) and PRA CP14/26 (the PRA Consultation Paper) (together, the Consultation Papers).

The proposals build on the

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