Review and compliance support
The SM&CR was launched in 2016, initially applying to banks, building societies, credit unions and PRA-designated investment firms, and extended to insurers and solo-regulated firms in subsequent years. The SM&CR aims to reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence.
Whilst firms have effectively embedded their SM&CR into “business-as-usual”, the regime is currently undergoing review and SM&CR reform as part of the UK government’s broader financial services agenda.
The FCA and PRA announced “Phase 1” reforms in April 2026 and, subject to legislation, will consult on a further package of “Phase 2” reforms. In this changing environment, it’s a good time for firms to revisit their SM&CR arrangements – to assess whether they align to regulatory requirements and appropriately applied to your firm – and identify opportunities to streamline.
How can we help
SM&CR health check review
A high-level, desk-based review of your SM&CR arrangements to identify any gaps, weaknesses or regulatory risks. The review will also consider the latest SM&CR reforms and identify opportunities to enhance, streamline, and strengthen your SM&CR framework.
SM&CR deep dive review
An in-depth, independent assessment of your governance framework and SM&CR arrangements to evaluate both regulatory compliance and overall effectiveness. Beyond compliance, the review will consider how individual accountabilities and responsibilities under SM&CR align with the firm’s wider governance framework.
Particular focus will be given to the interaction between Senior Managers, board committees, and collective board responsibilities, ensuring that accountability and responsibility is appropriately allocated while supporting effective oversight and challenge.
The assessment will identify any gaps, overlaps, ambiguities, or areas of regulatory and governance risk, together with opportunities to strengthen accountability, improve governance effectiveness, and streamline existing arrangements.
Training
We provide bespoke training to boards, senior management, compliance or HR teams, helping you to stay up to date with evolving requirements and SM&CR reforms. Training can be delivered as board briefings, standalone workshops or part of a wider learning and development programmes.
SME support to internal audit functions
Our SM&CR specialists provide targeted SME support to complement and enhance your internal audit team. We offer flexible solutions tailored to your specific needs and desired level of support, ranging from SME-led planning workshops, specialist input for selected audit areas to the delivery of end-to-end SME-led audits.
How our SM&CR specialists can help
Our specialists support firms with SM&CR health checks, independent compliance reviews, governance assessments, training and regulatory change programmes. Whether you are responding to recent SM&CR reforms, preparing for future changes or seeking assurance over your existing arrangements, we can help identify any gaps or weakness and strengthen accountability.
