Understanding the Initial Reforms to the U.K. Senior Managers Regime

The U.K. Financial Conduct Authority (FCA) and His Majesty’s Treasury have been working on initiatives to make the U.K. regulatory regime more flexible and proportional. In April 2026, the FCA issued Policy Statement 26/6 (PS26/6), which sets forth the FCA’s first set of reforms to the U.K. Senior Managers and Certification Regime (SMCR). PS26/6 recalibrates the SMCR to prioritize efficiency and proportionality, but without altering the regulations’ fundamental principles or reducing the regulatory or personal liability risks associated with senior management roles. At a program presented by the Alternative Investment Management Association, Dechert partner Jason Butwick and senior counsel Richard Frase discussed the changes effected by PS26/6, which include updated size thresholds and timelines; new guidance on rules and reporting requirements under the Code of Conduct in the FCA Handbook; revised guidance on regulatory references; and changes to the so-called “12‑week rule.” This article synthesizes their remarks. See our two-part series on the SMCR: “Responsibilities of Senior Managers” (Jun. 25, 2019); and “Certification Regime and Conduct Rules” (Jul. 9, 2019).

To read the full article

Continue reading your article with a PELR subscription.