Is Your Annual Certification Process Actually FCA-Ready? The Assessment Template You Need

Every year, FCA-regulated firms go through the motions of annual certification — and every year, the FCA finds firms that can't evidence what they've actually done. Certification under SMCR isn't just a box-ticking exercise. It's a legal obligation, and when things go wrong, the consequences land directly on senior managers.

In this episode, we're cutting through the complexity of the annual certification requirement and showing you exactly what a well-structured Annual Certification Assessment Template looks like — and why having one in place could be the difference between a clean regulatory record and an uncomfortable conversation with your supervisor at the FCA.

What we cover in this episode:

We start with the basics — who actually needs to be certified, what "fitness and propriety" genuinely means under the SMCR framework, and why so many firms are still getting this wrong years after SMCR came into force across the full financial services sector.

We then walk through the structure of a robust Annual Certification Assessment Template — the sections that matter, the evidence you need to gather, the conditional fit and proper determinations that firms routinely miss, and how to document your reasoning in a way that would stand up to regulatory scrutiny if challenged.

We discuss the difference between a certification process that looks right on the surface and one that is genuinely defensible — because the FCA's supervisory work has made clear that they are looking beyond policies and procedures to the quality of the evidence that underpins them.

We also cover some of the most common failure points we see when reviewing firms' certification frameworks — including incomplete fitness and propriety assessments, missing financial soundness checks, inadequate consideration of criminal records and regulatory history, and certification sign-offs that aren't properly linked to role-specific conduct risk.

Why this matters right now:

The FCA has been explicit in its supervisory priorities that individual accountability is at the heart of its regulatory agenda. SMCR was designed to ensure that people in positions of responsibility can be held to account — and the annual certification requirement is one of the most important mechanisms for making that accountability real and demonstrable.

Firms that treat annual certification as an administrative formality are exposed. Not just to regulatory censure, but to the reputational and operational consequences of having certified individuals in post who should not have been — or worse, of being unable to demonstrate why they were certified at all.

The practical takeaway:

By the end of this episode, you'll have a clear picture of what a best-practice Annual Certification Assessment Template should contain, how to structure your firm's certification process to meet FCA expectations, and what documentation you need to maintain to evidence your decisions.

If you want a ready-built solution, our Annual Certification Assessment Template is available to download directly from Compliance Consultant at complianceconsultant.org — built by qualified regulatory consultants who know what good looks like, ready to use, and designed to integrate with your existing SMCR framework.

Who this episode is for:

This episode is essential listening for HR professionals, compliance officers, MLROs, Chief Risk Officers, and any senior manager with oversight responsibility for SMCR certification at their firm. Whether you're at a large authorised firm or a smaller directly authorised business, if you have certified persons on your register, this episode is for you.

Visit us at complianceconsultant.org or call us on 0800 689 0190.

References: FCA SMCR — Certification Regime (FCA Handbook, FIT, SYSC 27); FCA Finalised Guidance FG20/1 — Certain aspects of the FCA's supervisory approach to the certification regime; PRA/FCA Joint Consultation on SMCR implementation.