To apply for approval to perform a Senior Management Function, a firm regulated by the FCA or PRA submits Form A (or Form E for internal transfers) through the FCA’s Connect portal, pays a £280 fee for a standalone submission, and waits up to three months for a decision. The application must be accompanied by a Statement of Responsibilities, ten years of employment history, a recent criminal records check, and regulatory references covering the previous six years. Getting any of those elements wrong is the fastest way to stall the assessment clock.
Choose the Right Form Before You Start
The form you need depends on whether the candidate is new to the firm or already approved somewhere in the group.
Form A covers new appointments and comes in two versions. Use the long Form A if the candidate has never held a senior management or controlled function, has been out of an approved role for six months or more, or has had any change to their fitness and propriety since their last approval. The short Form A applies only when a previously approved person is moving into a new SMF role and nothing material has changed in either their employment history or their fitness and propriety disclosures. Any change in either area pushes the application back to the long version.
Form E covers internal transfers, where an approved person is ceasing one controlled function and taking on a different one within the same firm or group. Existing approval does not shortcut the paperwork. Form E still requires a fresh Statement of Responsibilities, an updated CV, a role description, an organisational chart, a skills gap analysis, an induction programme, and a learning and development plan naming the individual monitoring the candidate’s progress. Enhanced scope firms must also supply the firm’s management responsibilities map and any handover material.
What You Need to Gather Before Submission
Ten Years of Employment History
The long Form A asks for ten years of employment history: the nature of each role, employer details, responsibilities held, and reasons for leaving. Any gaps must be explained. Unexplained blanks are one of the most common reasons an application gets kicked back for further information, and each information request pauses the statutory three-month clock.
A Recent Criminal Records Check
Before submitting, the firm must obtain a criminal records check under Part V of the Police Act 1997. For UK-based candidates that means a standard Disclosure and Barring Service check. FCA rules require the check to have been completed no more than three months before the application submission date; if it is older, the firm must explain why. Controlled function roles are exempt from the Rehabilitation of Offenders Act 1974, so spent as well as unspent convictions will appear on the certificate and need to be addressed in the application.
Regulatory References
The firm must request regulatory references from the candidate’s current employer and any employer from the previous six years, as required by SYSC 22 of the FCA Handbook. These references must disclose any information relevant to the candidate’s fitness and propriety, including serious misconduct regardless of when it occurred. Where a previous employer is itself an SMCR firm, it must answer a standardised set of questions covering disciplinary history, fitness concerns, and conduct rule breaches.
Your Own Fit and Proper Assessment
The firm must be satisfied that the candidate passes the Fit and Proper test before it submits. The FCA does not run this assessment for you after receiving the form. The FIT sourcebook sets three criteria the assessment must cover: honesty, integrity and reputation; competence and capability; and financial soundness. Any civil litigation, bankruptcy, or previous regulatory investigation must be disclosed with supporting detail. Providing inaccurate or incomplete information is a criminal offence and will almost certainly extend the assessment timeline.
The Statement of Responsibilities
Every SMF application must include a Statement of Responsibilities setting out exactly what the candidate will be accountable for. This document is the legal record tying the individual to specific areas of the firm’s operations, so vague language is a red flag for assessors. The statement must align with the firm’s management responsibilities map, which shows how all senior management responsibilities and FCA-prescribed responsibilities are distributed across the leadership team.
Under SYSC 24.2, firms must allocate each applicable FCA-prescribed senior management responsibility to one or more SMF holders. Prescribed responsibilities include overseeing the firm’s compliance with the senior managers regime itself, managing certification regime obligations, and ensuring regulatory references are handled properly. The allocation must make clear who owns each responsibility. A firm generally cannot assign prescribed responsibilities to someone approved only for the “other overall responsibility” or “other local responsibility” functions.
Submitting Through Connect
All applications go through Connect, the FCA’s online submission portal. Within three weeks of submission, the FCA will normally either assign a case officer or give a date by which one will be assigned. Progress can be tracked by signing into My FCA and opening the relevant application under “My Applications.”
A standalone Form A attracts a category 1 fee of £280. No separate fee is charged if the Form A is submitted as part of a wider application, such as a new authorisation or a variation of permission. Confirm the current fee schedule in FEES 3 Annex 15 of the FCA Handbook before submitting; categories and amounts can change each fee year.
What Happens After You Submit
The Three-Month Clock
Section 61 of the Financial Services and Markets Act 2000 gives the regulator three months from the date it receives the application to reach a decision. If the application arrives alongside a Part 4A permission application, the deadline extends to whichever of the two ends later. The clock pauses whenever the regulator issues a formal request for additional information, so an incomplete application can run well beyond three months in practice.
Interviews
The FCA may invite the candidate for an interview, particularly when it identifies fitness and propriety concerns it cannot resolve on paper, or where the firm’s size and market impact warrant closer scrutiny. Interviews are most likely for senior roles at large listed firms: chief executive (SMF1), chief risk officer (SMF4), compliance oversight (SMF16), chair of the governing body (SMF9), and senior independent director (SMF14). The FCA tells the candidate in advance which areas it wants to explore. Expect questions about the candidate’s understanding of their regulatory responsibilities, the firm’s business model and risk environment, governance and controls, and the firm’s approach to the Consumer Duty.
Possible Outcomes
If the application succeeds, the FCA issues a notice of approval and the individual can begin performing the function. Approval may be granted with specific conditions attached. If the FCA moves to refuse, it must issue a warning notice setting out its reasons, and the applicant has the right to make representations before a final decision notice is issued.
The Common Reasons Applications Stall
Three problems account for most delays. Employment gaps without explanation trigger information requests that pause the statutory clock. A Statement of Responsibilities written in vague or generic language forces assessors to seek clarification, and a Statement that does not match the firm’s management responsibilities map is worse still. Inaccurate or incomplete fitness and propriety disclosures not only extend the timeline but expose the applicant and the firm to criminal liability. Building the application around clean employment records, specific accountability language, and a candid fit and proper picture is the single biggest lever a firm has over how long approval takes.
Approval Is Not the End
Once approved, an SMF holder carries a statutory Duty of Responsibility under the Financial Services and Markets Act 2000, is bound by four senior manager conduct rules on top of the individual conduct rules that apply to all SMCR staff, and is subject to ongoing fitness and propriety assessment by the firm. Under Section 63 of the Act, the firm must notify the FCA if it forms the view that there are grounds on which the regulator could withdraw an individual’s approval. The application itself opens the regulatory relationship rather than closing it.