Internal transfers

Use Form E for internal transfers if an an approved person (including an SMF holder) needs to cease one or more controlled functions and apply for approval for a different one.

As Form E is for candidates already within a firm, you’ll see a reduced set of questions.

  • 2

    Evidence to support your application

    You must also upload supporting evidence, such as:

    • Skills gap analysis, learning and development plan, and induction programme.
    • Organisation chart for your firm.
    • List of directorships (if applicable).
    • Fitness and propriety evidence: full explanations of any factors that you’ve mentioned in Form A or Form E that might affect the candidate’s fitness and propriety.

    It is up to you whether to submit all your supporting evidence in separate documents, or within 1 supplementary document with a clear contents page.

    Check what supporting evidence you need to provide.

    (Dual-regulated firms should check what supporting evidence to provide on the Bank of England website[4].)

    Help with your application

    Contact us if you have a question about what to include in your application.

    Phone: 0300 500 0597

    If you’re outside the UK, phone: +44 207 066 1000

    Use text relay if you have a hearing or speech impairment: (18001) 0207 066 1000

  • 3

    Application fees

    Usually, you’ll pay a category 1 fee[5] if you submit Form A or E as a standalone application (just for the SMF).

    You will not be charged if you’re submitting Form A as part of a wider application, for example:  

    You can make the payment via Connect[3].  

    Find out more about fees in our Handbook[9]

  • 4

    After you apply: what to expect

    When we start our assessment, we’ll email your firm with the name and contact details of your case officer.

    If we need more information or details, we:

    • Will send you a request.
    • May phone your firm or arrange a meeting to outline our concerns.

    Be prepared to submit full and detailed responses within the requested deadlines.

    If we need to interview the candidate, we will let you know what topics we want to discuss in advance.  

    We’ll acknowledge when we hear from you and aim to respond promptly with a full reply.

    Find out more about how we assess applications[10]

    See our latest processing times for applications[11]


  • Common reasons for delays

    We must decide on an application within 3 months of receiving it.  

    Your application could take longer if we need to ask for more information.

    Common reasons for delays include:

    Find out more about our processing times[12]


    What you need to provide

    Expand the sections below for extra guidance.


    Sections in the application form

    Supporting evidence

    You must also upload supporting evidence:

    It is up to you whether to submit all your supporting evidence in separate documents, or within 1 supplementary document with a clear contents page.

    (Dual-regulated firms should check what supporting evidence to provide on the Bank of England website[18].) 

    Enhanced and dual-regulated firms

    Enhanced category firms and all dual-regulated firms except insurance special purpose vehicles (ISPVs) and firms in run off should also provide:

    Optional evidence

    To avoid delays and address any potential gaps, you may also want to include:

     


    Paper applications

    A few applications still need to be sent on paper. These include:

    You only need to send 1 paper application to the relevant regulator – either to the PRA for their SMFs or to the FCA for ones we regulate.  

    If your function is:

    If you want to apply for a paper exemption, contact us[20].

    If you need help, call us on 0300 500 0597


    Corporate applications

    Firms can become an SMF if they are a corporate body that acts as either a director or partner within the governance structure of a firm. This may include a:

    In most cases, individuals at the applicant firm become SMF holders.

    However, it is possible for a separate corporate body to be acting in a way that meets the definition of performing an SMF and be considered a partner. Where this is the case, individuals at the corporate entity acting as a partner are assessed and that corporate entity is approved as a partner.


    What a good application looks like 

    1. 1

      Be transparent from the start

      Disclose all relevant matters on your application, including potential adverse information such as misconduct.

      Show how you’ve addressed any potential risks that may arise in appointing the candidate, and why you’re satisfied that the candidate is fit and proper to perform the role(s) in question.

      If in doubt, disclose everything.  

      Failure to do so may:

      • Impact adversely on our view of the candidate’s ongoing fitness and propriety.
      • Mean we refuse the application, resulting in a warning notice being issued to both the candidate and your firm.
         
    2. 2

      Detailed application form

      Make sure you support your application with all necessary evidence when you submit.

      Complete all the sections in the application form and give as much detail as possible.

      (If there’s not enough space in the form, attach extra evidence or supporting documents separately.)

    3. 3

      Tailor how you show the candidate is fit and proper

      Be clear on how you as a firm have reached the conclusion the candidate is fit and proper.

      Check that your training plans are tailored to address any specific skills gaps identified for the candidate.

      If any adverse information has been disclosed, make sure you explain in as much detail as possible when answering the fitness and propriety questions.

    4. 4

      Fill in any gaps

      Explain any gaps and/or anomalies, such as:

      • Gaps in the candidate’s employment history.
      • Any disciplinary action relating to a previous role.
    5. 5

      Time commitments and conflicts of interest

      Consider the role’s time commitments and any conflicts of interest with the candidate’s other positions or interests.  

      Explain how the firm and candidate will manage these. Please provide specific details rather than just stating these issues have been considered.

      Remember to list all the candidate’s directorships (and former directorships covering the last 10 years). 

    6. 6

      Be prepared to give us extra details

      We may ask you to provide more information. To avoid delays, be ready to submit responses within the requested deadlines and provide full and clear replies.

      Consider adding a second contact name under ‘additional information’, to make sure you don’t miss our requests.


    Useful terms

    First published: Last updated: 12/03/2025


    Source URL: https://www.fca.org.uk/firms/senior-management-functions/how-apply

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