FCA Directory Persons: What Solo-Regulated Firms Must Submit
When the Senior Managers and Certification Regime (SMCR) was extended to all solo-regulated firms in December 2019, it introduced a new public register alongside the existing Financial Services Register. That register — the FCA Directory — lists certified staff, non-Senior Manager directors, and certain sole traders at regulated firms, making their roles visible to the public and to other firms.
The Directory matters to small firms for two reasons. First, there is a legal obligation to submit accurate data and keep it current. Second, the FCA uses the Directory as a supervisory tool — it provides transparency about who is performing regulated roles at each firm, which means gaps or stale entries draw attention. This guide explains who directory persons are, what data you must provide, and how the ongoing update and attestation obligations work.
What is the FCA Directory?
The FCA Directory is a publicly accessible database, hosted on the Financial Services Register, that provides information about individuals performing regulated roles who are not themselves directly approved by the FCA. Senior Managers are separately listed as approved persons on the main Register. The Directory covers everyone else who falls within the SMCR population.
The FCA created the Directory to close a transparency gap in the previous Approved Persons Regime. Under the old regime, certified staff — the broad group of employees whose roles could harm customers if performed badly — were not publicly visible at all. The Directory changes this: anyone can search for a named individual and see whether they hold a certified role at an FCA-regulated firm, what function they perform, and when they took up that role.
Who is a directory person?
The FCA defines three categories of directory persons:
1. Certified staff — individuals performing Certification Functions at the firm. These are roles defined in the FCA Handbook that can cause significant harm to customers or the firm if performed badly. Common Certification Functions at small firms include:
- Significant Management function (running a significant business unit — for example a proprietary trading desk or a unit with revenue, capital or risk exposure that is substantial for the firm)
- Client Dealing function (advising retail customers on investments, mortgages, or general insurance, or dealing/arranging deals with clients)
- Functions requiring qualifications (roles the FCA's Training and Competence sourcebook requires a qualification for, such as giving investment advice)
- Managers of certification employees (line-managing anyone who performs a Certification Function)
- CASS Oversight function (for firms that hold client money or client assets)
A small IFA where the directors advise clients directly will typically have those directors certified for the Client Dealing function. Note that the systems-and-controls roles (finance, risk and internal audit) are Senior Management Functions under SUP 10C, not Certification Functions — at a small core firm someone overseeing compliance or risk at scale is more likely to fall under the Significant Management certification function than a dedicated systems-and-controls approval.
2. Non-Senior Manager directors — both executive and non-executive directors who are not performing a Senior Management Function. At most small firms, all directors who are performing any executive role will already hold an SMF, but where a firm has non-executive directors who are not approved as SMF9 (Chair) or similar, they fall into the Directory.
3. Sole traders and appointed representatives performing client-facing business requiring qualifications — where the individual deals with retail clients in a role that requires professional qualifications.
Who is NOT a directory person?
Ancillary staff — receptionists, administrators, cleaners, security staff — are not covered. Neither are individuals who only perform roles with no client or regulatory impact. Limited Scope firms have a narrower obligation: non-approved board directors at Limited Scope firms are not subject to the full fit and proper requirements and are not directory persons.
What data must you submit?
For each directory person, firms must submit:
| Data field | Notes |
|---|---|
| Full name | Including any previous names |
| Roles and functions | With start dates (and end dates when the role ends) |
| Activities undertaken | The regulated activities performed |
| For customer-facing roles requiring qualifications | Engagement methods, workplace location, professional body memberships |
The data is submitted via Connect (My FCA). Firms can submit individual entries manually or upload a CSV template for multiple individuals.
When to submit
Solo-regulated firms were required to have submitted all directory persons data by 31 March 2021. If your firm was newly authorised after that date, you are required to submit directory persons data as part of your firm authorisation process or shortly after.
The 7-business-day update obligation
This is the obligation most commonly missed at small firms. Whenever anything changes about a directory person's data — they take on a new function, they leave the firm, their role changes, they change their name — you must update the Directory within 7 business days of the change taking place.
In practice, this means your compliance process needs to flag Directory updates alongside the standard HR and onboarding workflow. Common triggers:
- A new hire starts a Certification Function role → submit within 7 business days
- An existing certified staff member is promoted to a Senior Manager Function → their Directory entry ends (they move to the main Register as an approved person) → update within 7 business days
- A certified staff member leaves the firm → end-date their Directory entry within 7 business days
- An individual changes their name → update within 7 business days
If you miss the 7-business-day window, the FCA sends a late return notification and charges a £100 administrative fee. Persistent non-compliance can result in supervisory action.
The annual attestation
In addition to the 7-day update obligation, firms must complete an annual attestation confirming that their Directory data remains "up to date and accurate." The attestation must be completed within 12 months of the last time you updated the data.
This means that if you go a full year without any Directory updates (because your certified population has been stable and no changes have occurred), you still need to submit the attestation confirming that the existing data is still accurate.
The attestation is also submitted via Connect (My FCA). A Senior Manager at your firm is accountable for ensuring the obligation is met — at most small firms, this sits with whoever holds SMF16 (Compliance Oversight).
Common mistakes at small firms
Missing end-dates when staff leave. The Directory is a live database. If a certified staff member leaves and their entry is not end-dated, they continue to appear as active at your firm. This creates reputational risk and, if the individual has moved to another firm, can cause issues with that firm's fit and proper assessment.
Not knowing who needs certifying. At small IFAs and mortgage brokers, the certified population typically includes anyone who directly advises retail clients. Firms sometimes assume that because everyone holds an SMF (which is possible at very small firms), certification is not relevant — but unless each person's SMF covers their advice activities, they need to be separately certified.
Treating the Directory as a one-time submission. The Directory requires ongoing maintenance. A compliance calendar entry that fires annually for the attestation and at every onboarding/offboarding is a practical way to stay current.
Submitting incomplete data for customer-facing roles. For individuals in roles that require qualifications (typically client-facing investment or mortgage advice), you must submit their professional body memberships. Missing this data means the Directory entry is incomplete.
How the Directory connects to regulatory references
When your firm hires a new certified staff member from another regulated firm, the Directory is one of the tools another firm's compliance officer might check to verify the candidate's history of regulated roles. It is not a replacement for a regulatory reference — the Directory only shows public role data, not disciplinary history — but it provides a baseline check on whether the candidate's account of their regulated roles is consistent with the public record.
For a broader picture of the SMCR obligations at small firms, see our SMCR plain-English guide.
This guide covers FCA Directory Persons obligations for solo-regulated firms under SMCR. It is intended as a practical overview, not legal advice. For authorisation and registration queries, contact the FCA directly.
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