FCA PS26/6 SMCR Review: What Insurance Brokers and MGAs Need to Do Now
- Roland Romata
- May 4
- 7 min read
On 22 April 2026, the FCA published Policy Statement PS26/6, confirming the first phase of reforms to the Senior Managers and Certification Regime. Most changes came into force two days later, on 24 April 2026. Further changes follow in July and September. Phase 2, which requires primary legislation, is expected later in 2026 or into 2027.
The FCA published Policy Statement PS26/6 on 22 April 2026. Most of the Phase 1 changes came into force two days later. Further changes land in July and September, and Phase 2 (which requires primary legislation) is expected later in 2026 or into 2027.
For insurance brokers, MGAs, and all SMCR firms, the picture is mixed. Some of this is genuinely useful. Some of it creates new obligations. And none of it softens the underlying expectation that individual accountability needs to be demonstrable and evidenced.
This article runs through what has changed, when it applies, and what your firm should actually do about it.
What has changed from 24 April 2026
Criminal records checks: longer validity, fewer repetitions
The validity period for criminal records checks for SMF candidates has been extended from three months to six months. Firms also no longer need to repeat a check for someone moving internally or within a group, where an appropriate check has already been done.
For anyone who has recruited into a senior role recently, the three-month window was a recurring headache; slippage in appointment timelines or internal moves between group entities could trigger duplicative costs and friction that served no real compliance purpose. Six months gives you room to work with.
Practical note: The FCA’s application forms won’t be updated to reflect the six-month validity until 10 July 2026. The rule applies now, but the form wording is temporarily out of step. If you’re relying on the new window before July, keep a note of the rule change reference (PS26/6) on the relevant file.
The 12-week rule: a more workable framework for interim cover
This is one of the most significant practical changes, particularly for MGAs and smaller firms where interim cover arrangements are common.
Under the previous rule, firms had 12 weeks to submit an SMF application and obtain FCA approval. In practice, this often forced firms into premature SMF applications under pressure of the deadline, or created risk of breaching the rule where approval timelines were uncertain.
Under the revised rule, firms now have 12 weeks to submit the application. The individual can continue in the SMF role until the FCA determines the application. This removes the cliff-edge pressure on approval timing.
Statements of Responsibilities and Management Responsibilities Maps: batched updates
Solo and dual-regulated firms can now notify changes to Statements of Responsibilities on a batched basis, up to every six months. Previously, changes had to be notified promptly as they occurred. Only the latest version needs to be submitted.
For MGAs and smaller broker firms where SoR changes are triggered by personnel movements, restructuring or changes in business model, this reduces the administrative overhead of maintaining and notifying multiple individual updates throughout the year.
To be clear though: this is about the formal FCA notification, not your internal records. The expectation that firms maintain accurate governance documentation as changes happen hasn’t moved
Prescribed Responsibilities: new guidance on allocation and splitting
The FCA has issued additional guidance on Prescribed Responsibility allocations, including circumstances in which splitting a PR between multiple SMFs may be appropriate. Guidance also clarifies that PRs can be allocated beyond the 'most likely' examples in the Handbook where the allocation genuinely reflects the firm's seniority and authority structure.
For insurance firms with lean governance structures (particularly smaller MGAs and brokers) this additional flexibility on how PRs can be allocated is helpful context for firms that have found the rigid Handbook examples do not reflect how their business actually operates.
What changes on 10 July 2026
SMF18: more flexibility on Prescribed Responsibilities
From 10 July 2026, SMF18 holders (Other Overall Responsibility Function) at solo-regulated firms will be able to hold any Prescribed Responsibility. This removes previous restrictions on which PRs could be allocated to the SMF18 role, giving firms more flexibility to align their PR allocations with how the business is actually run.
For firms where the SMF18 carries significant operational weight (common in smaller MGAs and brokers) this enables governance documentation to reflect reality more accurately rather than forcing allocations into categories that do not fit.
Enhanced firm thresholds: some firms may move category
The financial thresholds that determine whether a firm falls within the Enhanced SM&CR category are increasing by approximately 30%, with a new five-year mechanism for future threshold adjustments to keep pace with inflation.
In practice, this means some firms that were previously classified as Enhanced SM&CR firms will move down into the Core category. Enhanced firms are subject to more detailed requirements: full Management Responsibilities Maps, more granular PR allocations, and a higher level of FCA scrutiny. Moving out of Enhanced reduces the volume and complexity of those obligations.
Certification Regime: overlapping roles removed
Approximately 15% of existing certification roles involve overlapping or duplicate requirements. From 10 July 2026, the FCA will remove these duplicate requirements, reducing the number of individuals who need to hold multiple certifications for effectively the same function.
The FCA will itself remove duplicate roles from the Financial Services Register and the Directory. Firms do not need to take action to trigger this (but firms should review their own internal records to ensure they reflect the simplified certification structure once the change takes effect).
Directory update deadline: extended for most updates
The deadline for updating the Financial Services Register / Directory will extend from 7 to 20 working days for most updates. The 7-working-day deadline is retained for reporting staff departures, reflecting the higher consumer harm and fraud risk associated with individuals who have left a firm remaining listed as active.
For insurance firms managing frequent role changes, this 20-day window provides a more realistic operational timeline for keeping Directory records accurate.
What changes on 1 September 2026
From 1 September 2026, SMCR is aligned with the FCA's wider framework on non-financial misconduct, following PS25/23 ('Tackling non-financial misconduct in financial services').
The FCA is treating non-financial misconduct (including bullying, harassment, and discriminatory behaviour) as a potential indicator of regulatory risk, particularly where it calls an individual's integrity, judgement, or ability to comply with professional standards into question.
For insurance firms, this means that conduct and culture issues that might previously have been treated purely as HR matters can now be relevant to Senior Manager fitness and propriety assessments and Conduct Rules obligations. Firms should ensure their disciplinary and investigation processes capture and record non-financial misconduct in a way that is consistent with FCA expectations, and that conduct assessments in FIT reviews consider this broader scope.
Phase 2: what is coming and when
Phase 2 requires changes to primary legislation. HM Treasury has confirmed it intends to remove the Certification Regime from the Financial Services and Markets Act 2000, including the annual recertification requirement. This would give the FCA and PRA the power to introduce replacement rules, rather than being constrained by the FSMA framework.
The government has also proposed reducing the number of Senior Management Functions that require formal FCA pre-approval, and removing legislative requirements concerning Statements of Responsibility.
The Financial Services Bill is expected to be announced in the King's Speech on 13 May 2026. The FCA has indicated it expects to consult on Phase 2 rule changes before the end of 2026. For most insurance firms, Phase 2 will not require immediate action
What insurance firms should do now
Given that most Phase 1 changes are already in force, the immediate priority is ensuring your firm has reviewed its existing SMCR framework in light of the changes. The following actions are relevant for most insurance brokers, MGAs and related firms:
Immediate (before end of May 2026)
Review your existing criminal records check process and update it to reflect the new 6-month validity period and removal of the requirement for internal moves.
If you have any individuals currently covering SMF roles under interim arrangements, confirm whether the 12-week rule applies and ensure Senior Manager Conduct Rules obligations have been communicated to the covering individual in writing.
Review your SoR update process. You can now batch changes for notification to the FCA every six months; but your internal records must remain current as changes occur.
Review your Prescribed Responsibility allocations in light of the new guidance. If existing allocations do not reflect the firm's actual governance structure, this is a good moment to correct them.
Before 10 July 2026
Check whether your firm's current financial metrics mean you may move from Enhanced to Core SM&CR category under the revised thresholds. Confirm your classification against the PS26/6 thresholds. Do not change your framework until you have confirmed the position.
If you have individuals holding multiple overlapping certifications, map which roles will be affected by the July changes. The FCA will make some Directory changes automatically, but your internal records should be updated to reflect the simplified structure.
Update your Directory update process to reflect the new 20-working-day deadline for most changes — and brief your team on the fact that the 7-day deadline for departures is unchanged.
Before 1 September 2026
Review your FIT assessment and annual review processes to ensure they incorporate non-financial misconduct as a relevant consideration, consistent with PS25/23.
Brief your HR and compliance teams on the alignment between SMCR conduct obligations and non-financial misconduct. Disciplinary and investigation records should capture conduct issues in a form that is accessible for FIT assessments if needed.
A word on evidence
PS26/6 reduces some administrative requirements. It does not reduce the expectation that firms can demonstrate individual accountability. The FCA's core test remains: if the regulator asked you today who is responsible for a particular area of your firm's conduct, could you show a clear governance record?
For insurance firms, this means the changes in PS26/6 are an opportunity to simplify and improve your SMCR documentation. Use the additional flexibility to make your governance records more accurate, more proportionate, and easier to maintain consistently.
If your SMCR documentation has not been reviewed in the last 12 months, PS26/6 is a practical prompt to do so. See how RegZone.io can support you with this.
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