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Extension of implementation period for SM&CR

Wednesday, July 1, 2020

The FCA has agreed with the Treasury that the deadline for solo-regulated firms to undertake the first assessment of the fitness and propriety of Certified Persons prior will be extended. 

Solo-regulated firms were previously required to have undertaken the first assessment prior to 9 December 2020, exactly one year after the SM&CR replaced the Approved Persons Regime. However, the new deadline will be 31 March 2021, with the extension being aimed at providing respite to those firms hit by the Coronavirus pandemic. 

The FCA have stressed that all firms should continue with their programme of work and those firms who can certify staff earlier than 31 March 2021 should do so. Firms should note that details of certified staff will start to appear on the new Financial Services Register from 9 December 2020. 

To maintain consistency of dates in relation to SM&CR, the FCA is also consulting on the following requirements which they propose extending from 9 December 2020 to 31 March 2021: 

  • the date the Conduct Rules come into force;
  • the deadline for submission of information about Directory Persons to the Register.


Our View

We believe that many firms will have this well in hand despite the Covid-19 situation.

We would suggest that, where possible, firms should take a proactive approach towards the assessment of certification staff and work towards the original 9 December 2020 where possible.

Action Required By You

  • For information and action as appropriate;
  • ATEB can help with SM&CR implementation, including Conduct Rules training - contact us if you would like to discuss.