Apply for a senior management function

Find out how to apply for approval to perform a senior management function (SMF).

Anyone who performs an SMF needs to be approved by us (or the Prudential Regulation Authority (PRA)) before they can start their role.

See a list of SMF roles in our Handbook[1]

Submit your application

We expect your firm to be prepared to submit a full and complete application on day 1.

Check you’re ready to submit[2]

Giving us false or misleading information may be a criminal offence.

All applications must include:

Completed form (including the candidate declaration and a statement of responsibilities for the role).
Any supporting documents (such as explanations for any adverse information).

You’ll need to pay a fee when you submit the application.

Find out how to avoid common delays

Check what a good application looks like

Steps: apply online

1
Application form
Complete the relevant form using our online system, Connect[3].
You’ll be shown different questions on the form depending on whether the candidate has been approved before.
An appropriate individual should complete the application on behalf of your firm and the candidate you're applying for, but the candidate should check the form before you submit.
Complete all the sections and, where possible, give detailed explanations (or consider attaching a supporting document with more information). This can help avoid delays later on.
New senior manager functions
Use Form A if you need to approve someone to take on a new SMF.
You’ll see a longer version of Form A if the candidate has:
- Not previously held a senior management or controlled function.
- Not been approved for senior management or controlled functions for 6 months or more.
- A change to their fitness and propriety since their last approval.
Form A covers sections such as:
- Candidate's details and declaration.
- Role description.
- Employment history for the last 10 years.
- Statement of responsibilities (SoR).
- Competency assessment.
- Capacity and conflicts assessment.
- Fitness and propriety questions.
- Directorships in the last 10 years.
- Regulatory references check.
- Criminal record checks.
Check what you need to provide for each section.
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:

Incomplete applications.
Not explaining how responsibilities are allocated in enough detail.
Criminal records checks and regulatory references not completed before the firm applies
Inadequate skills gap analysis (including not explaining in enough detail how you will address any gaps).
Out of date management responsibilities map.
Directorships not fully disclosed.
Inadequate information on conflicts of interest.
Not enough information about how candidates will have time to carry out their role without being overstretched.
Lack of timely responses from firms to follow-up questions.

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

Role description

Be very clear what the candidate is responsible for – this underpins how you’ve assessed them as competent.

Employment history

We need a history of your previous employment and key responsibilities for the last 10 years.

You’ll need to:

List past roles in reverse chronological order.
Explain all gaps, including education, career breaks or gardening leave.
Include the reason for leaving each employer.
Make sure you have gathered regulatory references (where required).

If there were any issues on leaving that could affect the candidate’s fitness and propriety, explain the circumstances in the ‘Fitness and propriety’ section.

We may contact previous employers.

Leaving out relevant details may lead to your application being delayed.

Although a CV is not mandatory, you can also attach one if you think it would be helpful.

Statement of responsibilities (SoR)

Every SMF holder needs a statement that clearly sets out what they are responsible for and accountable for. This is required under the Financial Services and Markets Act.

A statement of responsibilities (SoR) is a document that:

Describes each responsibility clearly.
Is practical and concise.
Is self-contained – not cross refer to other documents, attachments or links.

It will cover prescribed responsibilities (PRs) and other responsibilities, such as customer service or marketing.

For firms that need to have a management responsibilities map (MRM) – the SoR must be consistent with your MRM.

If a senior manager holds multiple SMFs:

At the same firm, they will only need 1 SoR, but this must clearly describe all of their responsibilities.
Across different firms within a group, they will need 1 SoR per firm.

For more on SoRs, see SUP 10C.11[13] in our Handbook.

Changes to responsibilities

You must also keep the SoR up to date, and resubmit it to us whenever there’s a significant change to a senior manager’s responsibilities, for example, if the firm needs to:

Add or remove a prescribed responsibility (PR) for a senior manager.
Change how responsibilities are shared between senior managers.

Check what counts as a significant change in SUP 10C[14] of our Handbook.

Prescribed responsibilities (PRs)

Prescribed responsibilities (PRs) are specific responsibilities defined in SYSC 24 of our Handbook that a firm must assign to its senior managers. They are in addition to the inherent responsibilities that are an essential part of a senior manager’s role.

We prescribe these responsibilities to make sure a senior manager is accountable for key conduct and prudential risks.

Firms must assign specific prescribed responsibilities (PRs) to a senior manager, except for:

Limited scope firms.
European Economic Area (EEA branches) that are operating in the UK under the financial services contracts regime[15].

Authorised fund managers have additional PRs.

For a full list, see SYSC 24 of our Handbook[16]

Criminal record checks

If you have not got a criminal record check when you apply, your application may be rejected (unless you’re a sole trader).

Your application must include the:

Date of the criminal record check.
Details of any criminal records shown on the certificate.

Do not include a copy of the criminal records check certificate when you submit the application.

If the criminal records check was completed over 3 months ago, tell us how your firm has satisfied itself the candidate is fit and proper when you fill out Form A.

Tell us if the candidate lives, or has worked, in a country where you cannot get a criminal record check.

Supporting evidence

You must also upload supporting evidence:

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.

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

Skills gaps analysis and learning and development (L&D) plan

This must be comprehensive and specific to the role and candidate.

We often see skill gaps analysis documents with a scoring system against the candidate’s knowledge or development areas – but without explaining what the scores mean, or how that determination was reached.

This makes it difficult for us to understand how you considered the individual as competent.

Consider:

If the firm is currently undertaking remediation activity or addressing material issues which the candidate will be accountable for, how does the candidate’s skillset and experience show competence to oversee these activities
If the firm is undergoing transformation – whether operational or cultural – what experience does the candidate have to lead transformation projects?
How do the candidate’s skills and experience complement the firm’s strategic vision?

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:

Management responsibilities map (MRM).
Handover document (or tell us if it’s a new role).

Management responsibilities map (MRM)

Check that the responsibilities match the ones allocated in the statement of responsibilities (SoR).

Make sure the MRM meets our requirements – it needs to:

Outline the senior management team’s prescribed responsibilities.
Show clear reporting lines.

Remember – it is your responsibility to keep MRMs up to date at all times.

Handover document

Saying 'a handover has taken place' is not enough.

We need to see a reasonable summary showing the handover that has, or will, take place.

This applies to dual regulated and solo enhanced firms.

For more on handover procedures, see SYSC 25.9[19].

Optional evidence

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

Any investigation outcomes.
Personal statements (as evidence of rehabilitation, for example).

CV (optional unless you are a dual-regulated firm)

CVs need to be up to date, showing a complete history of the candidate’s current and previous employment and their roles.

This should also include their:

Job titles.
Duration of employment.
Responsibilities.
Achievements.
Education.
Professional qualifications.

Paper applications

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

Adding or changing senior management functions (SMFs) for approved persons who are corporate partners.
Occasionally, other extenuating circumstances (such as a market-sensitive application).

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:

PRA led, only submit to the PRA (this includes PRA-led applications that include FCA functions; the PRA will send us any relevant information).
FCA led, only submit to us.

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:

limited liability company (LLP)
limited company (LTD)
public limited company (PLC)

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.

Apply to approve a corporate body

If you're applying to approve a corporate body, you cannot do this online through Connect.

You can either:

Download a paper Form A[21] or Form E[22] via our Handbook.
Contact us[21] and we’ll send you a paper-based form to fill out.

Where the criteria is met, you must provide details in the application form of how your corporate body meets the basic requirements to be an SMF manager (see SUP 10C.3.11 G[23] in our Handbook).

You’ll also need to include:

The place and date of incorporation.
Voting rights.
Copies of the partnership agreement, if the corporation is a partnership.
Names of all directors/partners at the corporate body.
Details of the governance and interaction the corporation has with your firm.
Personal details and answers to the fitness and propriety questions for 2 senior individuals of the corporate body.

A senior member of the corporate body needs to sign the candidate declaration on Form A.

What a good application looks like

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

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

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
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

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

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

Appropriate individual

An ‘appropriate individual’ is someone approved for a senior management function (SMF), or someone that your firm delegates the authority to contact us on its behalf.

Where this happens, you should keep records of which individuals are authorised to sign on your firm's behalf.

Controlled functions

Controlled functions relate to regulated activities carried out by a firm that are specified by us or the PRA.

You need approval before you can carry out a controlled function.

For FCA-regulated firms, controlled functions might be carried out by either:

Senior management functions (SMF) holders under the senior managers and certification regime.
Appointed representatives on behalf of a principal firm.

Read our Handbook definition[24]

Prepare to apply for a Senior Manager Function (SMF)[2]

How we assess senior management functions[11]

First published: 12/03/2025 Last updated: 12/03/2025

Apply for a senior management function

On this page

Submit your application

Steps: apply online

Application form

New senior manager functions

Internal transfers

Evidence to support your application

Help with your application

Application fees

After you apply: what to expect

Common reasons for delays

What you need to provide

Sections in the application form

Changes to responsibilities

Supporting evidence

Enhanced and dual-regulated firms

Optional evidence

Paper applications

Corporate applications

What a good application looks like

Be transparent from the start

Detailed application form

Tailor how you show the candidate is fit and proper

Fill in any gaps

Time commitments and conflicts of interest

Be prepared to give us extra details

Useful terms

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Senior management functions[25]

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