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SMCR Phase 1 is in force: what changed on 24 April 2026

SMCR Phase 1 is in force: what changed on 24 April 2026

The FCA published PS26/6 and the PRA published PS12/26 on 22 April 2026; most Phase 1 SM&CR changes took effect on 24 April 2026. They apply to all solo- and dual-regulated SM&CR firms, including third-country branches; dual-regulated firms must read both statements. Next, FCA improvements to regulatory reporting and processes apply from 10 July 2026, and PRA system changes to long and short Form A and Form E will not be implemented until 10 July.

Why operational teams should care

Phase 1 changes the workflows you already run — 12-week cover, Statements of Responsibilities, Directory, certification, criminal-record checks and regulatory references — even where Connect and PRA Form A/E wording have not caught up.

If you treat 24 April as the whole package you will miss later clocks: 10 July reporting, forms, Enhanced thresholds and overlapping certifications; 30 July Directory cleanup of overlapping certification functions; and 1 September COCON alignment with PS25/23 (named on the PS26/6 next-steps page). Dual-regulated firms also split FCA and PRA reporting of Senior Manager Conduct Rule breaches by people covering an SMF under the 12-week rule.

Operational consequences:

  • 12 weeks to submit an SMF application, not 12 weeks to obtain approval; Senior Manager Conduct Rules apply to the cover person
  • Criminal-record checks valid for six months; no CRC for certain internal or intra-group SMF moves
  • SoRs and MRMs notified within six months; only the latest version if several changes fall in the window
  • Directory: 20 working days for most updates; 7 working days still for leavers
  • Regulatory references: FCA guidance now points to four weeks, not six
  • Dual-regulated: PRA Form L from 24 April; Form A and Form E systems later

Both regulators say a broader Phase 2 depends on HM Treasury legislation and a later 2026 consultation. Do not put a Phase 2 date in the project plan.

SM&CR Phase 1 requirements by business type

The two policy statements overlap; they are not identical.

Business type From 24 April 2026 Still waiting Official references
Solo-regulated SM&CR firms 12-week rule as a submission deadline; Conduct Rules on the cover person; six-month CRC; SoR/MRM six-month notification of the latest version; certification guidance (digital / appraisal cycle); Directory 20/7 split; four-week reference guidance 10 July 2026: SMF18s at solo firms may hold any prescribed responsibility; Enhanced financial thresholds up 30%; overlapping certification functions removed. 30 July 2026: Directory overlapping-function change. 1 September 2026: remaining PS25/23 COCON pieces FCA PS26/6; PS26/6 PDF Tables 1–2
Dual-regulated banks, insurers, designated firms (incl. third-country branches) All of the above plus PRA Rulebook and SS28/15, SS35/15, SS5/21. SMF7 restated (controllers and representatives; PRA may identify SMF7s). Form L for 12-week-rule Conduct Rule breaches. Resolution administrators exempt. Insurers: Key Function Holder uses the SMF application, not a second Form M PRA Form A and Form E system changes, including CRC validity on those forms, not implemented until 10 July PRA PS12/26; FCA PS26/6
Enhanced-scope solo firms Remain Enhanced on current thresholds Recalculate from 10 July 2026: AUM £65bn; intermediary regulated-business revenue £45m; consumer-credit lending revenue £130m; five-year CPI mechanism PS26/6 PDF Table 2

Operational tip: CRC rules changed on 24 April. The forms will not show the six-month validity until 10 July. Keep a local record of which CRC you relied on.

Step-by-step: initial project plan

Step Action What operational staff must deliver Official reference
1 Split the clocks One-page calendar: 24 April live rules; 10 July reporting/forms/thresholds/overlapping certifications; 30 July Directory; 1 September PS25/23 COCON. Do not mark 10 July items as done FCA PS26/6 “Next steps”; PRA PS12/26 §§1.23–1.25
2 Rewrite the 12-week SOP 12 weeks to submit a complete SMF application (permanent or interim). Cover person may stay until determination. Conduct Rules from day one FCA PS26/6 Table 1; PRA PS12/26 §§2.3–2.15
3 Route cover-person breaches Solo: SUP 15 as soon as practicable (not annual REP008). Dual-regulated: PRA Form L from 24 April FCA PS26/6; PRA PS12/26 §§2.11–2.12, 1.25
4 Refresh CRC packs Six-month validity. No CRC for an existing SMF moving in the same firm or group (PRA: one-month gap allowed). Still do F&P for the new role FCA PS26/6 Table 1; PRA PS12/26 §§2.85–2.88
5 Change SoR/MRM cadence Notify no later than six months after a significant change; submit the latest version only. Live filing remains allowed FCA PS26/6 Table 1; PRA PS12/26 §§2.58–2.63
6 Recertification and Directory Digital certificates and appraisal-cycle recertification from 24 April. Directory 20 working days / 7 for leavers. Leave overlapping-function removal to 10 July (rule) and 30 July (Directory); the FCA will strip duplicate Directory roles FCA PS26/6 Tables 1–2
7 References, SMF7, Enhanced Four-week reference target; incomplete investigations only with reasonable grounds. Dual-regulated: re-run SMF7 against PRA examples — do not paste FCA SMF7 guidance onto a PRA firm. Solo Enhanced: do not drop out on 24 April; the 30% uplift is 10 July FCA PS26/6; PRA PS12/26 Chapter 3

Practical checklist for operational teams

  • Vacancy log – SMF gap date, 12-week submission deadline, interim vs permanent, Conduct Rule briefing for the cover person.
  • Form mismatch file – CRC and intra-group moves under the 24 April rules while Form A/E still show three-month wording until 10 July.
  • SoR/MRM tracker – Last significant-change date, next six-month filing, one “latest version” folder.
  • Directory SLA – Leavers in 7 working days; other fields in 20. Do not slow leavers to 20.
  • Certification evidence – Email or appraisal that records the F&P decision. Overlapping-function lists stay until 10 July / 30 July.
  • SMF7 list – Named in/out individuals and which regulator’s test you applied.

Common operational pitfalls

  • Treating 10 July reporting, Form A/E and Enhanced thresholds as if they took effect on 24 April.
  • 12-week cover without Senior Manager Conduct Rules, or breaches on the wrong form (REP008 instead of SUP 15; FCA channels instead of PRA Form L).
  • Applying FCA SMF7 guidance to a PRA-authorised entity, or the reverse.
  • Stripping overlapping certification functions from HR systems on 24 April, then failing the Directory until 30 July.
  • Building a Phase 2 date. Both statements point to Treasury legislation and a later 2026 consultation. No day is locked.

How GRT Consulting can help

GRT Consulting supports operational teams with:

  • Phase 1 clock maps (24 April / 10 July / 30 July / 1 September) against your SMF and certification population
  • 12-week rule, CRC and SoR/MRM procedure rewrites
  • Dual-regulated SMF7 / controller assessments against both PS26/6 and PS12/26

Contact us for a focused readiness review: T: +44 20 3695 9251 E: info@grtconsult.com Web: grtconsult.com

Sources

.., 28th April 2026

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