When a Senior Manager Leaves, the FCA Doesn't Accept "We Didn't Have a Process" as a Defence. SYSC 25.9 Requires the Firm to Ensure Every Incoming SMF Manager Has Everything They Need to Discharge Their Regulatory Responsibilities from Day One.
Senior management transitions are one of the highest-risk moments in any FCA-regulated firm's compliance lifecycle. The outgoing senior manager carries institutional knowledge, regulatory commitments, ongoing accountability for outstanding matters, and personal responsibility for a business area that doesn't pause when they leave. The incoming senior manager inherits all of that — plus the full weight of the Duty of Responsibility under section 66B of FSMA — from the moment they assume the function. If the handover is inadequate, the incoming senior manager is exposed. If there's no documented process, the firm is exposed. SYSC 25.9 of the FCA Handbook isn't guidance — it establishes the requirement that firms ensure incoming SMF Managers and their supervisors receive all information and materials reasonably expected to enable effective performance of their duties from commencement. For Enhanced Firms, the handover certificate and handover statement requirements add further formal obligations. This SMF Handover Policy gives FCA-regulated firms a complete, SYSC 25.9-aligned framework covering every element of the transition process: policy scope and SMF definition under section 59 FSMA, mandatory pre-commencement requirements, structured 4-week minimum handover timeline, core documentation requirements, training and competency assessment, roles and responsibilities across Board/CEO/outgoing and incoming SMF/HR, the SMF Manager Register with evidence requirements, a monitoring and KPI framework, and document control and version management — structured as a ready-to-implement policy with register templates and compliance checklists.
Senior management accountability doesn't transfer automatically. The process that makes it transfer properly is what this policy documents.
What's included: Full regulatory mapping — SYSC 25.9 (SMF handover: firm obligation to ensure incoming SMF Managers and supervisors receive all information and materials reasonably expected to enable effective performance from commencement), FSMA section 59 (FCA pre-approval requirement: no individual may perform an SMF without valid FCA approval/Form A submission), FSMA section 66B (Duty of Responsibility: presumption of senior manager breach in their area/reasonable steps defence), FCA Handbook SMCR (complete senior managers regime framework), SYSC 5.1 (pre-appointment training competency requirements), SYSC 9 (record-keeping: training records/competency assessments/handover documentation) · SMF definition framework — section 59 FSMA approval requirement/significant influence definition/Form A submission/temporary appointment rules/FCA pre-approval before commencement absolute requirement · Transition scenario coverage — new appointments/internal transfers between SMF roles/temporary and interim arrangements/role modifications affecting SMF responsibilities/succession planning arrangements — covering permanent/fixed-term/seconded/NEDs/consultants/contractors · Mandatory pre-commencement requirements — FCA regulatory notifications completed/incoming SMF comprehensive briefings (specific responsibilities/regulatory obligations/governance framework)/formal risk assessment (conflicts of interest/capacity constraints) · Handover timeline and documentation — 4-week minimum pre-transition commencement/outgoing SM obligations: current portfolio overview and key risk exposures/outstanding regulatory matters and commitments/key stakeholder relationships and contacts/pending decisions requiring immediate attention — formal transfer meetings (facilitated by Senior Management Team/written acknowledgement by incoming SM/copies retained for regulatory inspection) · Core documentation package — complete job description and Statement of Responsibilities/relevant regulatory framework including SMCR requirements/governance structure and reporting lines/risk management policies and procedures applicable to SMF role/compliance monitoring arrangements and escalation procedures/business continuity and operational resilience frameworks/training materials and system access credentials/supervisory support guidance for oversight responsibilities · Training and development framework — pre-appointment programme (regulatory knowledge/firm-specific policies/role-specific competencies per SYSC 5.1/evidenced before responsibilities assumed)/ongoing development (annual regulatory updates/industry training/leadership and management development/risk and compliance workshops)/competency assessment (initial evaluation on appointment/annual performance reviews against defined standards/regular technical knowledge assessment/remedial action documentation)/training records per SYSC 9 · SMF Manager Register — SYSC 25.9 compliance record (SMF function/name/appointment date/handover completion date/evidence reference)/Compliance function maintenance/5 business day update requirement for changes/documentary evidence: signed handover completion certificates/training records/competency assessments · Roles and responsibilities matrix — Board (ultimate policy responsibility/resource allocation/new SMF approval post-handover completion)/CEO (operational delivery/handover plan approval/competency certification before commencement)/Outgoing SM (comprehensive documentation preparation/mentoring and guidance/complete materials transfer/reasonable consultation availability)/Incoming SM (active participation/training completion/written acknowledgement before assuming full responsibilities)/HR (logistics coordination/comprehensive records/regulatory compliance throughout transition) · Monitoring framework — quarterly Compliance reviews: timeline adherence/documentation completeness and accuracy/materials quality/training programme effectiveness — KPIs: handovers completed within required timeframes/mandatory training completion rates/documentation quality scores/time-to-competency for new SMFs — monthly compliance reports to SMF16 · Policy governance — annual review minimum/regulatory change trigger/version control with audit trail/SMF holder approval requirement/distribution records and staff acknowledgement evidence
Built for: SMF16 Compliance Oversight holders, CEOs, HR Directors, and Company Secretaries at FCA-regulated firms who need a documented, board-approved SMF Handover Policy that satisfies SYSC 25.9 requirements, protects incoming senior managers from inheriting undefined accountability, and demonstrates to the FCA that every senior management transition is managed with the rigour the Duty of Responsibility demands.
When a Senior Manager Leaves, the FCA Doesn't Accept "We Didn't Have a Process" as a Defence. SYSC 25.9 Requires the Firm to Ensure Every Incoming SMF Manager Has Everything They Need to Discharge Their Regulatory Responsibilities from Day One.
Senior management transitions are one of the highest-risk moments in any FCA-regulated firm's compliance lifecycle. The outgoing senior manager carries institutional knowledge, regulatory commitments, ongoing accountability for outstanding matters, and personal responsibility for a business area that doesn't pause when they leave. The incoming senior manager inherits all of that — plus the full weight of the Duty of Responsibility under section 66B of FSMA — from the moment they assume the function. If the handover is inadequate, the incoming senior manager is exposed. If there's no documented process, the firm is exposed. SYSC 25.9 of the FCA Handbook isn't guidance — it establishes the requirement that firms ensure incoming SMF Managers and their supervisors receive all information and materials reasonably expected to enable effective performance of their duties from commencement. For Enhanced Firms, the handover certificate and handover statement requirements add further formal obligations. This SMF Handover Policy gives FCA-regulated firms a complete, SYSC 25.9-aligned framework covering every element of the transition process: policy scope and SMF definition under section 59 FSMA, mandatory pre-commencement requirements, structured 4-week minimum handover timeline, core documentation requirements, training and competency assessment, roles and responsibilities across Board/CEO/outgoing and incoming SMF/HR, the SMF Manager Register with evidence requirements, a monitoring and KPI framework, and document control and version management — structured as a ready-to-implement policy with register templates and compliance checklists.
Senior management accountability doesn't transfer automatically. The process that makes it transfer properly is what this policy documents.
What's included: Full regulatory mapping — SYSC 25.9 (SMF handover: firm obligation to ensure incoming SMF Managers and supervisors receive all information and materials reasonably expected to enable effective performance from commencement), FSMA section 59 (FCA pre-approval requirement: no individual may perform an SMF without valid FCA approval/Form A submission), FSMA section 66B (Duty of Responsibility: presumption of senior manager breach in their area/reasonable steps defence), FCA Handbook SMCR (complete senior managers regime framework), SYSC 5.1 (pre-appointment training competency requirements), SYSC 9 (record-keeping: training records/competency assessments/handover documentation) · SMF definition framework — section 59 FSMA approval requirement/significant influence definition/Form A submission/temporary appointment rules/FCA pre-approval before commencement absolute requirement · Transition scenario coverage — new appointments/internal transfers between SMF roles/temporary and interim arrangements/role modifications affecting SMF responsibilities/succession planning arrangements — covering permanent/fixed-term/seconded/NEDs/consultants/contractors · Mandatory pre-commencement requirements — FCA regulatory notifications completed/incoming SMF comprehensive briefings (specific responsibilities/regulatory obligations/governance framework)/formal risk assessment (conflicts of interest/capacity constraints) · Handover timeline and documentation — 4-week minimum pre-transition commencement/outgoing SM obligations: current portfolio overview and key risk exposures/outstanding regulatory matters and commitments/key stakeholder relationships and contacts/pending decisions requiring immediate attention — formal transfer meetings (facilitated by Senior Management Team/written acknowledgement by incoming SM/copies retained for regulatory inspection) · Core documentation package — complete job description and Statement of Responsibilities/relevant regulatory framework including SMCR requirements/governance structure and reporting lines/risk management policies and procedures applicable to SMF role/compliance monitoring arrangements and escalation procedures/business continuity and operational resilience frameworks/training materials and system access credentials/supervisory support guidance for oversight responsibilities · Training and development framework — pre-appointment programme (regulatory knowledge/firm-specific policies/role-specific competencies per SYSC 5.1/evidenced before responsibilities assumed)/ongoing development (annual regulatory updates/industry training/leadership and management development/risk and compliance workshops)/competency assessment (initial evaluation on appointment/annual performance reviews against defined standards/regular technical knowledge assessment/remedial action documentation)/training records per SYSC 9 · SMF Manager Register — SYSC 25.9 compliance record (SMF function/name/appointment date/handover completion date/evidence reference)/Compliance function maintenance/5 business day update requirement for changes/documentary evidence: signed handover completion certificates/training records/competency assessments · Roles and responsibilities matrix — Board (ultimate policy responsibility/resource allocation/new SMF approval post-handover completion)/CEO (operational delivery/handover plan approval/competency certification before commencement)/Outgoing SM (comprehensive documentation preparation/mentoring and guidance/complete materials transfer/reasonable consultation availability)/Incoming SM (active participation/training completion/written acknowledgement before assuming full responsibilities)/HR (logistics coordination/comprehensive records/regulatory compliance throughout transition) · Monitoring framework — quarterly Compliance reviews: timeline adherence/documentation completeness and accuracy/materials quality/training programme effectiveness — KPIs: handovers completed within required timeframes/mandatory training completion rates/documentation quality scores/time-to-competency for new SMFs — monthly compliance reports to SMF16 · Policy governance — annual review minimum/regulatory change trigger/version control with audit trail/SMF holder approval requirement/distribution records and staff acknowledgement evidence
Built for: SMF16 Compliance Oversight holders, CEOs, HR Directors, and Company Secretaries at FCA-regulated firms who need a documented, board-approved SMF Handover Policy that satisfies SYSC 25.9 requirements, protects incoming senior managers from inheriting undefined accountability, and demonstrates to the FCA that every senior management transition is managed with the rigour the Duty of Responsibility demands.
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