The Certification Regime (CR) is now live across all dual-regulated firms, as of 7 March 2017. March 2017 also marks the one year anniversary of the Senior Managers Regime (SMR). All dual regulated firms should now have identified their relevant populations across the SMR, CR and Code of Conduct employees. It is expected that firms have designed and implemented appropriate systems and controls with respect to the regimes.
The implementation of the Senior Managers and Certification Regime (SMCR) has not been without its challenges particularly with respect to:
- Identifying the appropriate employee populations
- Designing and implementing a robust framework to address the SMCR requirements with respect to decision making, systems and controls
- Understanding regulatory reporting requirements
- Addressing regulatory reference requirements.
We have documented the key challenge areas we observed when conducting Skilled Person engagements and SMCR assurance reviews. Download our guide to embedding SMCR to help guide you through these challenges.