Finding the right specialist for each Senior Manager Function
The Senior Managers and Certification Regime designates more than twenty senior manager functions, and the people who hold them are very different. A chief executive, a compliance oversight holder, a money laundering reporting officer, a board chair and a head of internal audit all carry personal accountability under the same regime, but they come from different talent pools, command different packages and are assessed by the FCA against different experience.
That is why SMF recruitment works best when it is matched to the function. This guide works through the senior manager functions one at a time and points to specialist hiring guides and recruitment services for each. The resources come from a group of specialist recruitment firms that divide the regulated market by level of leadership:
- SMF Capital: senior manager appointments across all of the FCA’s designated functions
- FD Capital: finance leadership, compliance and MLRO appointments, including fractional and interim cover
- Exec Capital: C-suite and executive senior managers
- NED Capital: chairs, independent non-executives and committee chairs
- Accountancy Capital: the qualified finance teams that support senior managers
If you are not yet sure which functions your firm needs, start with SMF Capital’s complete guide to SMF designations and its guide to which SMFs apply at which firm tier.
Executive functions
SMF1: Chief Executive
The SMF1 holder has overall responsibility for the firm’s conduct of business and is usually the first senior manager the FCA meets in an authorisation. Candidates need a track record of running a regulated business, and boards should expect close scrutiny of the appointment. Exec Capital’s SMF1 CEO hiring guide covers the search, and its guide to hiring a CEO who has never held an SMF role addresses one of the most common dilemmas. SMF Capital also covers SMF1 chief executive appointments.
SMF2: Chief Finance
The SMF2 holder is responsible for the firm’s financial resources and reporting. In regulated firms the role usually demands experience of prudential requirements, regulatory reporting and, in many sectors, client money. FD Capital specialises in SMF2 regulated CFO recruitment, and for firms going through authorisation it also recruits the finance lead for an FCA authorisation.
SMF3: Executive Director
SMF3 applies to executive members of the board who do not hold another designated executive function. Exec Capital’s SMF3 executive director hiring guide explains when the function applies and what the FCA looks for, and its executive director recruitment service handles the search.
SMF4: Chief Risk
The SMF4 holder leads the firm’s risk management function and, at larger firms, reports to a board risk committee. See Exec Capital’s SMF4 CRO hiring guide, FD Capital’s chief risk officer recruitment service and SMF Capital’s overview of the SMF4 chief risk officer function.
SMF5: Head of Internal Audit
The SMF5 holder leads internal audit and must be able to provide independent assurance to the board. Exec Capital’s SMF5 head of internal audit hiring guide sets out the profile and the search.
SMF24: Chief Operations
The SMF24 holder is responsible for the firm’s internal operations and technology, an increasingly important role as operational resilience expectations rise. See Exec Capital’s SMF24 chief operations hiring guide and SMF Capital’s SMF24 chief operating officer recruitment service.
Governance functions
SMF9: Chair
The SMF9 holder chairs the governing body and is responsible for leading the board’s oversight of the executive. Chair appointments draw on a distinct pool of experienced non-executives, and NED Capital’s guide to the SMF9 non-executive chair function covers what firms should look for.
SMF10 and SMF11: Risk and Audit Committee Chairs
At firms with board risk and audit committees, the chairs of those committees hold the SMF10 and SMF11 functions. Both need deep subject-matter experience and the independence to challenge the executive. NED Capital’s guide to the SMF10 and SMF11 risk and audit committee chair functions explains the roles and the search.
SMF14: Senior Independent Director
The SMF14 holder acts as a sounding board for the chair and an intermediary for other directors and shareholders. NED Capital’s guide to the SMF14 senior independent director function covers the role, and its independent non-executive director recruitment service supports wider board searches.
Required functions: compliance oversight and money laundering reporting
SMF16 and SMF17
Compliance Oversight (SMF16) and Money Laundering Reporting (SMF17) are required functions at most Core and Enhanced firms, and they are the senior manager appointments regulated firms make most often. At smaller firms one individual frequently holds both. These roles are also where demand for flexible arrangements has grown fastest.
- For part-time senior cover, FD Capital recruits fractional compliance officers, including fractional Heads of Compliance and MLROs holding SMF16 and SMF17.
- For permanent and interim hires, see FD Capital’s compliance recruitment and MLRO recruitment services.
- When a holder resigns unexpectedly, FD Capital’s guide to SMF16 and SMF17 temporary cover under the 12-week rule sets out the timetable.
- Sector specialists are covered by FD Capital’s pages on consumer credit and BNPL compliance recruitment, payments and e-money compliance recruitment and cryptoasset compliance recruitment.
- SMF Capital’s guide to SMF16 and SMF17 compliance oversight and MLRO appointments explains both functions in detail.
Other overall responsibility and client assets
SMF18 and client money oversight
SMF18 covers senior managers with overall responsibility for an area not otherwise covered by a designated function, and is often relevant where a firm holds client money or assets. FD Capital’s CASS recruitment service covers heads of client assets and SMF18 oversight roles, while Accountancy Capital recruits the CASS accountants who run client money reconciliations day to day.
Sector-specific functions
SMF19: Head of Third Country Branch
Overseas firms operating a UK branch need a senior individual to hold SMF19. Exec Capital’s guide to SMF19 head of third country branch recruitment covers the role.
SMF20 and SMF23: Chief Actuary and Chief Underwriting Officer
Insurers subject to the regime need specialist senior managers for their actuarial and underwriting functions. See Exec Capital’s guides to SMF20 chief actuary recruitment and SMF23 chief underwriting officer recruitment.
Beyond the senior managers
RDR-qualified advisers and certified staff
Many regulated firms also need certified staff, such as qualified financial advisers. SMF Capital recruits RDR Level 4 certified advisers alongside its senior manager work.
The finance team behind the senior managers
Senior managers are only as effective as the teams that support them. Accountancy Capital recruits financial controllers for FCA-regulated firms, fractional financial controllers for regulated firms and regulatory reporting specialists.
Pay, roles and live vacancies
- For pay benchmarks across the senior manager functions, see Exec Capital’s SMF salary guide.
- For an overview of each role, see Exec Capital’s SMF roles guide.
- For current senior manager vacancies, see the SMF Capital jobs board.
Permanent, interim or fractional?
Not every senior manager appointment needs to be a permanent, full-time hire. Interim senior managers are often used to cover a sudden vacancy, lead remediation or support a firm through authorisation, and since April 2026 the FCA’s reformed 12-week rule allows a cover individual to remain in post while an application for a replacement is decided. Fractional arrangements, where an experienced senior manager works for the firm part-time, have become common for compliance oversight and money laundering reporting at smaller firms, and are increasingly used for finance leadership too. The right choice depends on the function, the firm’s size and risk, and how quickly the role needs to be filled.
How to use this guide
Every senior manager appointment runs to the same broad timetable: define the role and its prescribed responsibilities, search and select, complete fitness and propriety checks, apply for FCA approval and onboard the new holder. Under the FCA’s 2026 reforms, regulatory references must now be provided within four weeks, and the statutory deadline for the FCA to decide a complete application remains three months. Planning ahead, and using a specialist for the specific function, is the best way to keep that timetable on track.
For the underlying rules, the FCA’s Senior Managers and Certification Regime pages are the definitive source, and the Financial Services Register shows who holds which function at every authorised firm.
Frequently asked questions
Which senior manager functions does my firm need?
It depends on whether your firm is Limited Scope, Core or Enhanced, and on its structure and permissions. Most Core firms need SMF1, SMF3, SMF9 where there is a chair, SMF16 and SMF17. SMF Capital’s guide to which SMFs apply at which firm tier is a good starting point.
Can one person hold more than one SMF?
Yes. At smaller firms one individual often holds both SMF16 and SMF17, for example. The individual must be approved for each function and have the time to perform them all.
Can senior manager roles be filled on a fractional basis?
Yes, particularly at smaller firms. Fractional compliance officers and MLROs holding SMF16 and SMF17 are increasingly common, provided the time commitment and support arrangements are proportionate to the firm’s size and risk.
How long does it take to appoint a senior manager?
Allow for the search, the candidate’s notice period and FCA approval. Several months is typical for a permanent appointment; interim cover can be arranged much more quickly.