FCA compliance e-learning courses for regulated firms - CISI CPD certified
Tap into over 70 e-learning modules with our FCA compliance course library. Equip your team with the necessary tools to navigate every aspect of FCA regulations, from high-level and conduct of business standards to thematic topics such as Consumer Duty, vulnerable customers, and operational resilience.
Our CPD-accredited modules include sector-specific learning for banking, investments, and mortgages, alongside a full set of FCA SMCR training courses.
Ensure your company’s FCA compliance
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Companies looking for an engaging, all-encompassing FCA course library.
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Over 70 training modules, with sector-specific versions for banking, investments, and mortgages.
Stay on the right side of FCA regulations
Our FCA Compliance course library is ideal for those looking to simplify the complexities of FCA regulations. Financial services firms face a particularly complex regime when it comes to compliance, and breaches can result in unwanted penalties or sanctions. Education is vital in ensuring your employees understand their roles and adhere to regulations set by the FCA. You can host our FCA course library on our fully managed LMS portal or use your own. Plus, you can customise this library by exploring our bespoke training plans.
About our learning styles
In-depth
These are our more detailed e-learning courses that include practice scenarios and typically last between 25 and 45 minutes.
Refresher
These targeted courses help reinforce your employees' knowledge and notify them of any updates they might not be aware of. These typically last between 15 and 20 minutes.
Express
Our focused training courses deliver employee learning in smaller chunks, typically lasting between 10 and 15 minutes.
Microlearning
These bite-sized animated training videos can be delivered as: standalone, embedded in detailed e-learning courses, or compiled into a learning path.
Dive deeper into our FCA courses
See what’s included in our FCA course library below. Looking for something specific? Use the search bar to find what you need. If you have any questions, reach out and tell us more about your requirements — we’re happy to help.
Good Outcomes for Vulnerable Customers
Companies have a legal obligation to identify the signs of vulnerability and ensure that vulnerable individuals are treated fairly.
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Overview of the Consumer Duty
The FCA's Consumer Duty is a new standard which addresses the conduct of firms.
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Meeting the Conduct Rules in FCA Solo Regulated Firms
The Conduct Rules are a fundamental aspect of the SMCR.
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Whistleblowing in Financial Services
Our Whistleblowing training course educates employees on reporting misconduct safely and ensures protection.
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Meeting the Conduct Rules in Dual Regulated Firms
The Conduct Rules are a fundamental aspect of the SMCR.
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Complaints Handling
The FCA has identified that the number of complaints submitted in the financial services sector has increased year on year in recent times in the UK.
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Introduction to the Consumer Duty
The FCA's Consumer Duty is a new standard which addresses the conduct of firms.
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Treating Customers Fairly
Treating Customers Fairly (TCF) applies to firms in the financial services industry.
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Personal Conflicts of Interest
The FCA states that a firm must manage conflicts of interest between itself and its customers or other clients.
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Introduction to UK Financial Regulation
NEDs are an important part of a firm's governance and provide independence and oversight.
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Operational Resilience
The FCA has made operational resilience a requirement for banks, building societies, PRA-designated investment firms, enhanced scope firms and other financial institutions.
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CASS Overview
The FCA's Client Assets Sourcebook (CASS) supports Principle 10 of the FCA's Principles for Businesses.
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Conflicts of Interest in Asset Management
The FCA outlines its expectations that asset management firms establish and maintain an effective framework to identify, control and review conflicts of interest.
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MCOB - General Standards
The Mortgage Conduct of Business (MCOB) for General Standards applies to all firms that deal with home finance.
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Principles for Businesses
The FCA's Principles for Businesses apply to all financial services firms in the UK regulatory system.
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Ethical Standards in Finance and Investment
The FCA's ethical standards apply to individuals in finance and investment.
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BCOBS - General Standards
The FCA Banking Conduct of Business Sourcebook (BCOBS) applies to all firms that accept deposits from banking customers in the UK.
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Training and Competence
Training and Competence (T&C) forms an important part of UK regulations under the FCA.
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Overview of SM&CR for FCA Solo Firms
Our SMCR Overview training course will help your employees understand the key steps needed to comply with the regime.
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COBS - Client Communications and Financial Promotions
The Conduct of Business Sourcebook (COBS) applies to financial firms in the UK that deal with client investments.
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CONC - Consumer Credit Regulations
The FCA's Consumer Credit sourcebook (CONC) applies to all firms engaged in credit-related regulatory activities in the UK.
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Introduction to the Senior Managers and Certification Regime (SM&CR)
The UK's financial services sector has been rocked over the past decade by scandals ranging from misselling to market manipulation.
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COBS - Client Categorisation
The Conduct of Business Sourcebook (COBS) applies to financial firms in the UK that deal with client investments.
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Payment Services Regulations
The Payment Services Regulations (PSRs) 2017 was introduced in 2018 and set the Payment Services Directive 2 (PSD2) in motion.
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Whistleblowing for Managers
Whistleblowing refers to disclosing corrupt, illegal or fraudulent activities committed by organisations.
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Appropriate Use of Communication Channels
Not all communication channels are appropriate for business purposes.
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Markets in Financial Instruments Directive II (MiFID II)
The Markets in Financial Instruments Directive (MiFID) originally aimed to increase competition and integration in markets for financial instruments.
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COBS - Dealing and Managing
The FCA Conduct of Business Sourcebook (COBS) applies to financial firms in the UK.
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Information Barriers
The flow of information in financial firms needs monitoring between businesses involved with private and public side activities.
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Senior Management Arrangements Systems and Controls
The Senior Management Arrangements Systems and Controls (SYSC) Sourcebook apply to authorised financial services firms.
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Conduct Rules for Senior Managers at Dual Regulated Firms
Under the Senior Managers Regime, all senior managers must comply with the FCA's six Individual Conduct Rules (ICRs) and four Senior Managers Rules (SMRs).
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MCOB - APRC, Shortfalls and Charges
The Mortgage Conduct of Business (MCOB) for the Annual Percentage Rate of Charge (APRC), shortfalls, and charges apply to home finance businesses.
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FSCS Deposit Protection
The Financial Services Compensation Scheme (FSCS) safeguards customers' finances.
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Complaints Handling for Managers
One of the three operational objections of the FCA is to protect consumers.
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Overview of SM&CR for Dual Regulated Firms
Our SMCR Overview training course will help your employees understand the key steps needed to comply with the regime.
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Fit and Proper Assessments
In order to perform a Senior Management Function (SMF), Senior Managers need to be approved by the FCA and, for dual regulated firms, the PRA.
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Conduct Rules for Non-Executive Directors (NEDs)
NEDs are an important part of a firm's governance and provide independence and oversight.
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Non-Financial Misconduct
Non-financial misconduct is behaviour that is unrelated to regulated activities, including serious offences such as harassment, bullying, sexual discrimination and sexual misconduct The FCA has indicated it is prepared to consider non-financial misconduct when assessing fitness and propriety.
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Conduct Rules for Senior Managers at FCA Solo Firms
Under the Senior Managers Regime, all senior managers must comply with the FCA's six Individual Conduct Rules (ICRs) and four Senior Managers Rules (SMRs).
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AIFM Regulations
The Alternative Investment Fund Managers Directive (AIFMD) was developed by the EU in order to create a harmonised framework of rules for regulating AIFMs.
Appointed Representatives Regulatory Responsibilities
The FCA expects companies to ensure all their appointed representatives know the provisions within the FCA handbook.
BCOBS - Distance Communications
The Banking Conduct of Business Sourcebook (BCOBS) applies to all firms accepting deposits from banking customers in the UK.
Benchmarks Regulation
The FCA defines a Benchmark as an index used to determine the value of or the amount payable under a financial instrument (or contract).
Breathing Space Regulations
Breathing Space Regulations apply to creditors whose debtors are eligible for additional time to repay their debt.
CASS 10 - CASS Resolution Pack
A CASS Resolution Pack (RP) contains a specific set of documents that helps speed up client money and assets return if a firm fails.
CASS 6 - Custody Rules
The rules and guidance in CASS 6 apply to a firm when it is safeguarding and administering custody assets.
CASS 7 and 7A - Client Money Rules and Client Money Distribution and Transfer
The rules and guidance in CASS aim to achieve the FCA's objective of ensuring that consumers are adequately protected.
CASS 8 - Mandates
Under the requirements of CASS 8, you must understand what a mandate is and how to deal with them.
CASS 9 - Information to Clients
Under the requirements of CASS 9, you are required to pass on certain information to clients, particularly where prime brokers, custody assets and client money are concerned.
CeMAP Competency Refresher
The Certificate in Mortgage Advice & Practice (CeMAP) is a UK specific qualification issued by the London Institute of Banking & Finance (LIBF).
COBS - Appropriateness
The FCA's Conduct of Business Sourcebook (COBS) applies to financial firms that deal with customer investments on an execution-only basis.
COBS - Client Communications High Risk Investments
The Conduct of Business Sourcebook (COBS) rules that relate to client communication apply to all promotional communications that investment firms have with their clients and prospects.
COBS - Suitability
The FCA Conduct of Business Sourcebook (COBS) applies to finance and investment firms in the UK.
Complaints Handling for the Mortgage Market
The FCA outlines complaints handling rules in the Dispute Resolution Sourcebook (DISP).
FX Global Code
The FX Global Code is a set of global principles of good practice in the foreign exchange market.
ICOBS - Cancellation and Claims in Finance
The Insurance Conduct of Business Sourcebook (ICOBS) applies to all non-investment insurance businesses.
ICOBS - Distance Communications
The Insurance Conduct of Business Sourcebook (ICOBS) for distance communications applies to all insurance firms that engage in distance marketing activity in the UK.
Introduction to the Perimeter Guidance Manual
PERG helps clarify when financial activities need FCA authorisation, as outlined by the Financial Services and Markets Act 2000 (FSMA).
MCOB - Advising and Selling
The Mortgage Conduct of Business (MCOB) Advising and Selling standards apply to businesses that advise on or arrange mortgage contracts, equity release transactions, home purchase plans or sale and rent back agreements.
MCOB - Disclosures
The Mortgage Conduct of Business (MCOB) for Disclosures applies to businesses involved in home finance transactions.
MCOB - Equity Release
The Mortgage Conduct of Business (MCOB) for Equity Release applies to businesses that make recommendations or provide personalised information to customers on equity release products.
MCOB - Financial Promotions
The Mortgage Conduct of Business (MCOB) for Financial Promotions applies to financial promotions in the home finance business.
Mortgage Credit Directive
The EU Mortgage Credit Directive (MCD) applies to all businesses dealing with first-charge, second-charge, and buy-to-let mortgages.
Outsourcing and Third Party Risk Management
As the risk inherent to business relationships grow, regulators have been drafting and implementing outsourcing and third-party risk management rules and guidance.
Packaged Retail and Insurance-based Investment Products (PRIIPs) Regulation in Finance
The Packaged Retail and Insurance-based Investment Product (PRIIP) Regulation affects retail investors who need to understand the complexities of these products.
Pensions Ombudsman Complaints Handling
In the UK, the Pensions Ombudsman handles pension complaints and disputes at no cost to members of occupational and personal pension schemes.
Prudential Regulation
Prudential Regulation applies to firms in financial services.
Responsible Lending and Affordability
Responsible Lending and Affordability are non-negotiable principles that underpin the UK's mortgage market reform.
SEC Rule 15a-6
To engage in securities transactions with United States (US) clients, non-US firms must comply with Rule 15a-6 requirements.
Sustainability Disclosure Requirements (SDR) and Investment Labels
The introduction of sustainability rules aims to enhance the transparency and credibility of financial products with sustainability objectives.
Swap Execution Facilities (SEFs) and Designated Contract Markets (DCMs)
Swap Execution Facilities (SEFs) and Designated Contract Markets (DCMs) exist as part of the US response to the financial crisis.
UCITS
Undertakings for the Collective Investment in Transferable Securities (UCITS) Directive aims to offer asset managers and investors greater business opportunities.
UK Money Markets Code
The UK Money Markets Code provides a set of principles to promote the integrity and effective functioning of the UK money markets.
Understanding Failure to Prevent Fraud (FTPF) in Financial Services
Failure to Prevent Fraud (FTPF) is a corporate offence that holds organisations criminally liable if they do not have reasonable measures in place to stop fraud committed by someone acting on their behalf.
Understanding Failure to Prevent Fraud (FTPF) in Financial Services for Managers
Failure to Prevent Fraud (FTPF) is a corporate offence that holds organisations criminally liable if they do not have reasonable measures in place to stop fraud committed by someone acting on their behalf.
SDR and Investment Labels
Sustainability-related claims in financial products must be clear, transparent and backed by evidence.
ICOBS - General Matters
The Insurance Conduct of Business Sourcebook (ICOBS) for general matters applies to all firms engaged in the insurance business.
ICOBS - Providing Information and Advising
The Insurance Conduct of Business Sourcebook (ICOBS) for Providing Information and Advising applies to insurance intermediaries.
Car Finance Mis-selling
The Financial Conduct Authority banned discretionary commission arrangements in car finance due to concerns about unfair interest rates.
Developing Secure Applications
The way companies build software and technology systems is evolving very rapidly.
Conduct Rule 1: Act with Integrity
Integrity is a fundamental principle in financial services, ensuring ethical conduct and maintaining customer trust.
Conduct Rule 2: Act with due skill, care and diligence
People working in financial services must act with due skill, care and diligence, ensuring their actions do not harm customers or the financial system.
Conduct Rule 3: Be open and cooperative with the FCA, the PRA and other regulators
Financial services firms and employees must be open and cooperative with regulators, including the Financial Conduct Authority and the Prudential Regulation Authority.
Conduct Rule 4: Pay due regard to the interests of customers and treat them fairly
Financial services professionals must always act in the best interests of customers and ensure they are treated fairly.
Conduct Rule 5: Observe proper standards of market conduct
Financial markets rely on trust, integrity and adherence to established rules and ethical behaviour.
Conduct Rule 6: Act to deliver good outcomes for retail customers
Financial services professionals must act in good faith, prevent foreseeable harm and support customers in achieving their financial objectives.
BCOBS - Distance Communications [Mutual]
The Banking Conduct of Business Sourcebook (BCOBS) applies to all firms accepting deposits from banking customers in the UK.
BCOBS - General Standards [Mutual]
The FCA Banking Conduct of Business Sourcebook (BCOBS) applies to all firms that accept deposits from banking customers in the UK.
ICOBS - Cancellation and Claims [Mutual]
The Insurance Conduct of Business Sourcebook (ICOBS) applies to all non-investment insurance businesses.
ICOBS - Distance Communications [Mutual]
The Insurance Conduct of Business Sourcebook (ICOBS) for distance communications applies to all insurance firms that engage in distance marketing activity in the UK.
ICOBS - General Matters [Mutual]
The Insurance Conduct of Business Sourcebook (ICOBS) for general matters applies to all firms engaged in the insurance business.
Payment Services Regulations [Mutual]
The Payment Services Regulations (PSRs) 2017 was introduced in 2018 and set the Payment Services Directive 2 (PSD2) in motion.
Principles for Businesses [Mutual]
The FCA's Principles for Businesses apply to all financial services firms in the UK regulatory system.
Treating Customers Fairly [Mutual]
Treating Customers Fairly (TCF) applies to firms in the financial services industry.
ICOBS - Providing Information and Advising [Mutual]
The Insurance Conduct of Business Sourcebook (ICOBS) for Providing Information and Advising applies to insurance intermediaries.
Financial Crime Prevention
Financial crime ranges from fraud, tax evasion, bribery, market abuse, insider dealing, money-laundering, to terrorist financing.
Conduct Risk
The FCA focuses on good customer outcomes and how a firm achieves this through staff conduct at all levels of the business.
Senior Management Arrangements Systems and Controls [Mutual]
The Senior Management Arrangements Systems and Controls (SYSC) Sourcebook apply to authorised financial services firms.
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Your questions, answered
FCA Handbook
Financial Crime
Fraud Prevention
Insurance
SMCR
Common FAQs
Which principle is most important in an insurance contract?
What is proximate cause in insurance?
How does the principle of indemnity work in real-life claims?
What types of firms are regulated under CONC?
How often should firms review their CONC compliance policies?
What triggers an FCA investigation into CONC breaches?
What kind of staff training is required to meet CONC standards?
How does insider trading affect businesses and investors?
What tools are used to detect insider trading?
How does the FCA regulate insider trading?
What is a Recognised Investment Exchange (RIE) and how is it regulated?
What steps can firms take to avoid FCA penalties?
How does the FCA monitor and detect market abuse?
What does FCA COBS stand for?
What is the main purpose of COBS?
Where can I find the full COBS rules?
Who needs to comply with COBS rules?
Who do the FCA Principles apply to?
How are the FCA Principles enforced?
What happens if a firm fails to notify the FCA of an issue?
How can firms ensure compliance with the FCA Principles?
How often should FCA Code of Conduct training be refreshed to remain effective?
How can firms tailor Code of Conduct training for high‑risk business areas?
What tools or technology can support ongoing compliance monitoring?
What steps can be taken to rebuild trust after a breach of the Conduct Rules?
Who needs to comply with CASS rules?
How often should firms review their CASS compliance procedures?
What role does staff training play in CASS compliance?
How can I log and track incidents of financial crime in my organisation?
How can I ensure my employees understand and comply with our internal policies in relation to financial crime?
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Can small businesses be held accountable under competition law?
Are informal conversations with competitors risky?
What are the consequences of breaking competition law?
How can companies prevent anti-competitive behaviour?
Does the Criminal Finances Act 2017 apply to non-UK companies?
What industries are most at risk under the Criminal Finances Act?
How often should businesses review their tax evasion prevention procedures?
Can small businesses be prosecuted under the Criminal Finances Act 2017?
What industries are most vulnerable to proliferation financing risks?
How can small businesses ensure compliance with proliferation financing regulations?
Are there international standards for combating proliferation financing?
What are “dual-use goods” and why are they significant?
How often should proliferation financing risk assessments be updated?
How can I ensure employees are aware of our Fraud Prevention policies and procedures?
How can employees report suspicions of fraud anonymously?
How can I make sure every employee has read and agreed to our anti-fraud and conduct policies?
How can I measure my employees’ awareness of fraud risks and identify gaps in understanding?
How can I provide employees with a safe and anonymous way to report suspected fraud?
Which principle is most important in an insurance contract?
What is proximate cause in insurance?
How does the principle of indemnity work in real-life claims?
What is SMCR?
Senior Managers Regime
This enforces a detailed and clear allocation of responsibilities between senior managers at each firm, with particular emphasis placed on key documents - 'Statements of Responsibilities' and 'Responsibilities Maps'. These help to record the distribution of responsibility to individual Senior Managers and to demonstrate to the regulators that there are no gaps or excessive overlaps.
Always bear in mind that Senior Managers have a statutory duty of responsibility "to take reasonable steps to prevent regulatory breaches in the areas of the firm for which they are responsible".
Certification Regime
This requires firms to check and confirm that employees performing roles relating to the firm's regulated activities are fit and proper, based on their qualifications, competence and personal characteristics.
Once this has been confirmed, the firm needs to issue them with a certificate that must be renewed every year.
Conduct Rules
This consists of a set of rules provided in the FCA's Code of Conduct Handbook (COCON) that covers all individuals: Senior Managers, Certified Persons and other employees.
What is the scope of the SMCR?
SMCR rollout waves
The SMCR has been rolled out in three waves:
Wave 1: Banks, building societies, credit unions and large investment firms in March 2016 (updated July 2018)
Wave 2: Extended to insurance firms (those regulated by the FCA and PRA) in December 2018
Wave 3: The remaining financial services firms (otherwise known as 'solo-regulated firms' since they are regulated only by the FCA, not the FCA and PRA) came under the scope of this regime in December 2019.
SMCR categories
The range of firms in the third wave is very diverse. Consequently, the FCA has grouped them into three categories to ensure that the regulation is proportionate to their sizes and activities:
Core: Firms that have to comply with the baseline requirements for solo-regulated firms
Limited scope: Firms that already had exemptions under the Approved Persons Regime, and are exempt from some requirements and require fewer senior management functions
Enhanced: Firms that have extra requirements - these are large, complex firms with potential impact on consumers or markets which warrant more attention from the FCA
What's needed to comply with SMCR?
- Statement of Responsibilities - Set out the areas for which each Senior Manager is personally accountable
- Responsibilities Map - This knits together the Statement of Responsibilities
- Pre-approval for all Senior Managers - obtain this from the regulators before they carry out their roles
- Duty of Responsibility - Ensure that Senior Managers understand their responsibilities and take reasonable steps to prevent regulatory breaches in their areas of responsibility
- Identify all Certified Persons - These are all material risk takers
- Fit and Proper Assessment - Of all Certified Persons, then re-assess on an annual basis
- Training - Of all those who are subject to the Conduct Rules
SMCR Training
Such training must result in employees gaining awareness and a broad understanding of all of the conduct rules, as well as a deeper understanding of the practical application of the specific rules which are relevant to their work.
To help with SMCR implementation, we have created a 3-step training model.
We provide a comprehensive set of SMCR training courses for all financial firms, including banking, insurance and solo-regulated firms.
Duty of Responsibility
Senior Managers have a statutory duty of responsibility "to take reasonable steps to prevent regulatory breaches in the areas of the firm for which they are responsible".
The FCA can take action against a Senior Manager (SM) where it can show that:
There was misconduct by the SM's firm,
At the time of the misconduct or during any part of it, the SM was responsible for the management of any of the firm's activities in relation to which the misconduct occurred, and the SM did not take such steps as a person in their position could reasonably have been expected to take to avoid the misconduct occurring or continuing.
The burden of proof for all these elements lies on the FCA. The SM does not need to show that they took reasonable steps - rather, it is for the FCA to prove that they did not. The defence against such action is if the senior manager can show that they took "the steps that are reasonable for a person in that position to take to prevent a regulatory breach from occurring".
Fitness and Propriety
The FCA must approve all senior managers, which assess whether they are fit and proper to perform the given function or responsibility.
Three key factors determine whether you are Fit and Proper:
Honesty, integrity and reputation
Competence and capability
Financial soundness
When determining a person's financial soundness, the FCA will not normally require a statement of assets or liabilities of the person. Limited financial means does not in itself affect the suitability of a person to perform an SMF.
When appointing a Senior Manager or Certified Person, firms must obtain a regulatory reference from all their past employers going back six years. This requirement also applies when appointing NEDs who are not Senior Managers.
For this purpose, firms need to retain records of disciplinary and fit and proper findings going back six years and not enter into arrangements that conflict with their disclosure obligations.
What are the SMCR Conduct Rules?
SMCR incorporates new high-level standards of behaviour that apply to almost all employees who carry out financial services activities in a firm. Some Conduct Rules apply to all employees, while others apply only to Senior Managers.
The Conduct Rules are intended to drive up standards of individual behaviour in financial services. By applying them to a broad range of staff, the FCA aims to improve individual accountability and awareness of conduct issues across firms.
Individual Conduct Rules (ICRs)
These apply to all employees, with the exception of ancillary staff, such as facility managers, personal assistants, receptionists, medical staff, IT and HR, who perform a purely non-financial service's role. These ICRs also apply to Non-Executive Directors.
ICR 1: You must act with integrity
ICR 2: You must act with due skill, care and diligence
ICR 3: You must be open and cooperative with the FCA, the PRA and other regulators
ICR 4: You must pay due regard to the interests of customers and treat them fairly
ICR 5: You must observe proper standards of market conduct
Senior Manager Conduct Rules (SMCRs)
These apply only to Senior Managers, including NEDs (SC 4 even applies to out of scope NEDs)
SC 1: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively
SC 2: You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system
SC 3: You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively
SC 4: You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice
What does SMCR Best Practice look like?
Stay up to date with SMCR best practices, industry insights and key trends across regulatory compliance, digital learning, EdTech and RegTech by subscribing to the Skillcast Compliance Bulletin.
3-Step SMCR Training Model
Whether you're new to the SMCR or benchmarking existing processes, our training model will help get your compliance training on track.
FCA Conduct Rules Training Aid
Our desk aid has ten tips on how to ensure your staff fully understand and adhere to conduct rules.
FCA COCON Breaches Desk Aid
Our desk aid reminds all of your staff fully of the ten easiest ways to breach the FCA Code of Conduct.
Operational Resilience Implementation Checklist
Ensure your firm follows the FCA guidelines for a compliant operational resilience programme.
Fit and Proper Training Presentation
Firms need to assess the Fitness and Propriety (F&P) of Senior Managers and Certified Persons when they are appointed and on an ongoing basis. Our F&P training presentation uses scenarios to help explain this further.
SMCR & Non-financial Misconduct
A lack of public confidence and some damaging press stories have renewed the FCA's focus on conduct, including non-financial misconduct. Find out more, including a free training module and a desk aid.
SMCR Solo-Regulated Firms Key Questions Answered
We answer the questions every solo-regulated firm has been asking.
SMCR Insurance Firms Key Questions Answered
We also answer the questions every insurance firm has been asking.
How to Evidence your SMCR Competence
If you cannot articulate what is adequate and competent within your firm, you simply won't be able to evidence SMCR compliance when the FCA comes knocking!
How to Prevent SMCR Training Damaging Staff Motivation
SMCR created a step-change in personal accountability, causing a headache, especially when dealing with those who've never been accountable before. That's why it's important to take steps to address any issues before they spiral out of control.
What are the SMCR Functions?
The Senior Managers Regime (SMR) applies to those who perform a Senior Management Function (SMF). The FCA has classified specific functions as SMFs, so that it knows who a firm's senior decision-makers are, and to make sure that firms clearly allocate specific responsibilities to those key individuals.
In certain circumstances, firms can have more than one individual performing a single SMF. However, the FCA expects that SMFs are only shared where it is justified and appropriate.
The list of SMFs that apply depends on the type of firm.
5.1 Governing Function SMFs
| SMF1 | Chief Executive | Core and Enhanced firms |
| SMF3 | Executive | Core and Enhanced firms |
| SMF7 | Group Entity Senior Manager | Enhanced firms only |
| SMF 9 | Chair (non-executive) | Core and Enhanced firms |
| SMF10 | Chair of the Risk Committee | Enhanced firms only |
| SMF11 | Chair of the Audit Committee | Enhanced firms only |
| SMF12 | Chair of the Remuneration Committee | Enhanced firms only |
| SMF13 | Chair of the Nominations Committee | Enhanced firms only |
| SMF14 | Senior Independent Director | Enhanced firms only |
| SMF27 | Partner | Core and Enhanced firms |
5.2 Required Function SMFs
| SMF16 | Compliance oversight | Core and Enhanced firms (and sole traders, authorised professional firms and oil market participants) |
| SMF17 | Money Laundering Reporting officer | Core and Enhanced firms and (and sole traders and oil market participants) |
| SMF18 | Other Overall Responsibility | Enhanced firms only |
| SMF29 | Limited Scope Function | Limited Scope firms (e.g. limited permission consumer credit firms, authorised professional firms, firms that intermediate insurance without this being principal business) |
The Overall Responsibility requirement means that an Enhanced firm will need to make sure that every activity, business area and management function has a Senior Manager with overall responsibility for it. This is to prevent an unclear allocation of responsibilities.
Overall Responsibility means that a Senior Manager:
- Has ultimate responsibility for managing or supervising a function
- Briefs and reports to the governing body about their area of responsibility
- Puts matters requiring decisions about their area of responsibility to the governing body
5.3 Systems and Control SMFs
| SMF2 | Chief Finance Function | Enhanced firms only |
| SMF4 | Chief Risk Function | Enhanced firms only |
| SMF5 | Head of Internal Audit | Enhanced firms only |
| SMF24 | Chief Operations Function | Enhanced firms only |
What are the required responsibilities under the SMCR Responsibilities
You need to be aware that there are more responsibilities for Senior Managers than just the ones found within each SMF's definition. The regulators have listed certain 'Prescribed Responsibilities' (PRs) that each firm is required to allocate between Senior Managers.
Each PR would generally be allocated to the Senior Manager who performs the SMF most closely linked to the given responsibility. PRs can be shared but not split between Senior Managers. Where responsibility is shared, it is recorded identically in each of the Senior Manager's Statements of Responsibilities.
If there is a breach, all Senior Managers sharing that responsibility may be required to demonstrate that they took reasonable steps to prevent or stop the breach.
The list of PRs that applies depends on the type of firm. Responsibilities (a), (b), (b-1), (d) below cannot be allocated to SMF 18 (Other Overall Responsibility) and responsibilities (j), (k), (l) below should be performed by a non-executive director if possible.
| (a) | Performance by the firm of its obligations under the SMR, including implementation and oversight | All firms |
| (b) | Performance by the firm of its obligations under the Certification Regime | All firms |
| (b-1) | Performance by the firm of its obligations in respect of notifications and training of the Conduct Rules | All firms |
| (d) | Responsibility for the firm's policies and procedures for countering the risk that the firm might be used to further financial crime | All firms |
| (z) | Responsibility for the firm's compliance with CASS (if applicable) | All firms |
| (c) | Compliance with the rules relating to the firm's Responsibilities Map | Enhanced firms only |
| (j) | Safeguarding and overseeing the independence and performance of the internal audit function (in accordance with SYSC 6.2) | Enhanced firms only |
| (k) | Safeguarding and overseeing the independence and performance of the compliance function (in accordance with SYSC 6.1) | Enhanced firms only |
| (l) | Safeguarding and overseeing the independence and performance of the risk function (in accordance with SYSC 7.1.21R and SYSC 7.1.22R) | Enhanced firms only |
| (j -3) | If the firm outsources its internal audit function, taking reasonable steps to ensure that every person involved in the performance of the service is independent from the persons who perform external audit, including supervision and management of the work of outsourced internal auditors, and management of potential conflicts of interest between the provision of external audit and internal audit services | Enhanced firms only |
| (t) | Developing and maintaining the firm's business model | Enhanced firms only |
| (s) | Managing the firm's internal stress tests and ensuring the accuracy and timeliness of information provided to the FCA for the purposes of stress-testing | Enhanced firms only |
| (za) | Responsibility for an AFM's assessments of value, independent director representation and acting in investors' best interests | Authorised Fund Managers |
Who is responsible for assessing competence?
What types of evidence can demonstrate competence?
How often should competence be reviewed?
Are Skillcast courses SCORM-compliant?
What other tools are needed beyond training?
Is our training content still compliant with the latest legislation?
- You can check the latest course content updates in our library updates page: https://www.skillcast.com/compliance-course-library-updates
- For major legislative changes, we:
- Will send you email alerts to ensure you are notified
- Offer you a free trial of newly created or updated content
- Host webinars with compliance experts to explain the changes and how our training supports your ongoing compliance
Can you translate our content into other languages?
What file types are supported by the Skillcast system?
Features |
Supported file types and details |
|
File Exchange |
File types: PDF, Excel spreadsheets, Word documents, SCORM and xAPI files, and compressed zip files. Max file size: Default is 1GB, can be increased to a max of 2GB |
|
SCORM files |
Versions: SCORM 1.2, SCORM 1.2 for Moodle, SCORM 2004 2nd, 3rd and 4th Edition. Max file size: 1024MB |
|
xAPI file |
Max file size: 2GB |
|
Videos |
File types: MP4 or MOV. Videos must be optimised, with a max file size of 100MB. If the file is bigger, our Design Team can help |
|
Images |
File types: jpg, png and gif. The file size should ideally be 100KB, but it can be up to 250KB |
|
CPD evidence |
File types: Word, PDF, Excel and CSV. File size: the limit should be whatever the portal config option is set to. Servers are set to max 2GB |
|
Policy documents |
PDF or Word File size: the limit should be whatever the portal config option is set to. Servers are set to max 2GB |
|
Offline activities evidence |
File types: PDF, DOC, DOCX, XLS, XLSX, CSV, PNG, GIF, JPEG, JPG, PPTX and MSG. File size: the limit should be whatever the portal config option is set to. Servers are set to max 2GB |
|
Client logo files |
File types provided by client: EPS, PDF, AI and SVG |
|
Registers |
PDF, DOC, DOCX, XLS, XLSX, CSV, PPT, PPTX, POT, PPA, PPS, JPG, JPEG, PJEPG, PNG, BMP, GIF, MP4, MOV, WMV, CPTX, CP, TXT, ZIP and MSG files |
|
Declarations |
JPG, JPEG, PNG, GIF, XLS and XLSX files |