Key takeaways

• The UK Financial Conduct Authority has issued consultation papers providing details on its extension of the Senior Managers and Certification Regime (SMCR) to almost all UK regulated financial services firms.  We expect insurers to have to implement the SMCR by late 2018, and other firms by mid to late 2019.
• In general, individuals approved under the current regime will automatically become senior managers under the SMCR where there is a corresponding senior management function.  A number of approved individuals will no longer require regulatory approval under the SMCR.