How do I keep the FCA notified as part of my obligations under SMCR?

For most scenarios where you are required to notify the FCA of changes within your business – you are required to submit a form. These different forms cover many potential activities – so we’ve pulled together a table with some definitions for you below:

Form Scenario
Long Form A
Application to perform a controlled function including SMFs
Short Form A
Application to perform a controlled function including SMFs
Form C
Notice of ceasing to perform controlled functions including SMFs – this form is used to cancel the approval for an individual.
Form D

Changes to personal information/application details and conduct breaches/disciplinary action related to conduct.

This form is used to notify the FCA of breaches of the conduct rules BY SENIOR MANAGERS, disciplinary action against senior managers and changes to personal information.

Form E

Internal transfer of a person performing a controlled function for solo-regulated firms.

This form is relevant for individual changing the approved function being performed.

Form I

Application for the variation of a conditional approval for the performance of an SMF.

Form J

Notification of significant changes in responsibilities of a Senior Manager – this form is used if there are significant changes to the Statement of Responsibilities of a Senior Manager.

Form K

Conversion notification form for FCA solo-regulated firms.  This form is used to convert existing approvals under the Approved Persons Regime to new functions under the SM&CR.

Form O
Notification of change to firm classification under the SM&CR.

Notification of Conduct Rule breaches and disciplinary action.

This form should be used to notify the FCA of conduct rule breaches by certification and conduct rules staff, or submit a nil return.

A template for a Senior Manager’s statement of responsibilities.

What forms should I use?

Form A

There are two versions of Form A – Long Form A and Short Form A.  The main difference between the two is that Long Form A must contain detailed information about fitness and proprietary whereas Short Form A does not.

The golden rule is that Long Form A can be used in ALL circumstances.  To that extent, always use Long Form A if you do not know which Form A to use.

When can I use Short Form A?

You may use Short Form A if you, or the candidate you are applying on behalf of:

  1. currently holds a Senior Management Function and is applying to take up another one in the same firm;
  2. currently holds a Senior Management Function at one firm and is applying to hold a similar one at another firm; or
  3. has resigned a Senior Management Function at one firm and is applying to hold a similar senior management function at another firm, provided that the initial Senior Management Function was not resigned more than six months ago.

When should I use Long Form A?

You must use Long Form A if you, or the candidate you are applying on behalf of, has

  1. never held a senior management function;
  2. not, in the last six months, held a Senior Management Function that is relevant to the one being applied for; or
  3. experienced a material change in fitness and proprietary since the submission of the initial Long Form.


You must use Long Form A if you are unable to determine whether Long Form A or Short Form A should be used.

Everything you wanted to know about SM&CR - but were afraid to ask!

New to SMCR – or need a hand getting up to speed withj SMCR compliance? This guide will help you understand and implement every part of the SM&CR. You’ll learn, amongst other things:

  • How firms are classified.
  • How to identify Certification Staff.
  • The Responsibilities of a Senior Manager.
  • Conduct Rules & how they apply to your role.

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