Information on individuals approved for SMF - February 2025

The number of SMF applications approved, approved with conditions, rejected, withdrawn or refused during 2024 can be found in the attached document (Annex A).

In considering the data, please note the following:

• The data provided relates to FCA-led Senior Manager Applications. We also work alongside the Prudential Regulation Authority (PRA) for Senior Manager applications that include PRA-designated controlled functions. Information about those cases can be directed to the PRA, if necessary, as it is the administrative lead for these.
• Human intervention is required to label cases appropriately. Given the volume of cases in the data provided, we have not undertaken a manual review to check for inaccuracies caused by human error. However, we do not consider that any unidentified inaccuracies would have a material impact on the data provided.
• We have three categories for applications that are not approved: rejected, withdrawn and refused.
• Rejections relate to administrative issues – e.g., we can reject incomplete applications.
• Firms and candidates can withdraw applications for several reasons. These include where they no longer consider an application is necessary or where we share concerns about an application, and it is subsequently withdrawn.
• Refusals are where the FCA has taken the decision to formally refuse an application. The volume of refusals is low as firms often prefer to withdraw an application ahead of a decision being made on an application. Details on our refusal process can be found here: https://www.fca.org.uk/firms/authorisation/apply/refusal-process[1].

We can confirm that we hold the information that you have requested. However, as the requested information will be published within the next few weeks, we are exempt from providing it to you in advance as we consider that section 22 (information intended for future publication) of FOIA applies.

For further details on why this exemption applies, please see Annex B below.

Section 22 (Information intended for future publication)

Section 22(1) of the Act states that information is exempt from disclosure if:

1. The information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),
2. The information was already held with a view to such publication at the time when the request for information was made, and
3. It is reasonable in all circumstances that the information should be withheld from disclosure until the date referred to in paragraph (a).

We consider that these three limbs have been met.

Section 22 is a qualified exemption and is subject to the public interest test.

We have therefore balanced the public interest for and against disclosure as required by FOIA and summarise these arguments as follows:

For disclosure

• Disclosing the data would increase public awareness of the FCA’s use of attestations as a supervisory tool.
• We are due to publish the updated quarterly data very shortly on our website.

Against disclosure

Overall, we consider that the public interest lies in favour of maintaining the exemption for the above reasons. We do not consider it to be in the public interest to release the information in advance of publication.