We have submitted a written response to questions 2b and 13 of the FCA’s consultation paper CP25/21 on the review of the Senior Managers and Certification Regime.
These questions focus on areas where firms would benefit from further guidance, as well as proposals concerning disclosures in regulatory references and their interaction with separate proposals on notifications to the FCA. Our response sets out our detailed views on these topics, identifying areas that may give rise to unfairness or impose unnecessary burdens, and offering constructive suggestions to support a more balanced and practical approach.
You can read our full response here.