FCA Form A: How Small Firms Apply for Senior Manager Approval

Every Senior Manager at an FCA-regulated firm needs the FCA's approval before they can start the role. Under the Senior Managers and Certification Regime (SMCR), that approval is applied for on Form A — the Application to perform senior management functions. For a small firm hiring a compliance officer, promoting a director into a Senior Management Function (SMF), or restructuring who is responsible for what, Form A is the gateway.

It is also one of the points where small firms most often get tripped up. The form itself is long, it has to be submitted alongside a Statement of Responsibilities, and the FCA has a statutory window in which to decide. Get the sequencing wrong and a new Senior Manager can end up unable to legally perform their role on day one. This guide explains what Form A is, when you need it, what goes in it, and how the approval process runs.

What is Form A?

Form A is the FCA's application to approve an individual to perform one or more Senior Management Functions. It is submitted through Connect (the FCA's online application system, accessed via My FCA). There are two versions — a "long form" and a "short form" — and which you use depends on whether the individual is already approved elsewhere and the nature of the application.

A Senior Management Function is a role the FCA has designated as carrying such significant responsibility that the person performing it needs to be individually approved and held accountable. At a small solo-regulated firm the common SMFs are:

SMF1 – Chief Executive
SMF3 – Executive Director
SMF16 – Compliance Oversight
SMF17 – Money Laundering Reporting Officer (MLRO)
SMF27 – Partner (for firms structured as partnerships or LLPs)
SMF29 – Limited Scope Function (for Limited Scope SMCR firms)

As the FCA's guide for solo-regulated firms notes, one person can hold more than one SMF — a common example is an SMF3 Executive Director who also acts as the SMF17 MLRO. The application still needs to name every function that person will perform.

When do you need to submit Form A?

You submit Form A whenever a person needs to be approved for a new SMF. In practice that means:

Hiring or appointing a new Senior Manager — for example bringing in an external compliance officer to hold SMF16.
Promoting an existing employee into a role that carries an SMF.
A person taking on an additional SMF they were not previously approved for.
Restructuring so that responsibilities move to someone who is not yet approved for the relevant function.

You do not use Form A to remove a Senior Manager — that is Form C, submitted within ten business days of the person ceasing the role. And you do not use Form A to make a minor change to an existing Senior Manager's responsibilities where no new function is involved — that is handled through an updated Statement of Responsibilities.

The pre-approval rule

The critical point is that approval must come before the person starts performing the SMF. A firm cannot appoint someone to a Senior Management role and then apply for approval afterwards. This is why the sequencing matters: if you are hiring a new compliance officer with a fixed start date, the Form A application needs to go in early enough for the FCA to assess and grant approval before that date.

Form A and the Statement of Responsibilities

Form A does not travel alone. When you apply for a Senior Manager to be approved, you must submit a Statement of Responsibilities (SoR) for that individual. The FCA's guide is explicit: "You will need to submit a SoR to us when applying for a Senior Manager to be approved (please use Form A). You will also need to keep the SoR up to date, and resubmit it to us whenever there's a significant change to a Senior Manager's responsibilities."

The Statement of Responsibilities is a single-document description of what that Senior Manager is actually responsible for, including any Prescribed Responsibilities allocated to them. It has to be clear, current, and consistent with the responsibilities held by the rest of the firm's Senior Managers — there should be no gaps and no unexplained overlaps. If you are new to the SoR, our Statement of Responsibilities guide walks through the structure and a worked example.

For a small firm, the practical workflow is:

Decide which SMF(s) the person will hold.
Draft their Statement of Responsibilities, allocating any Prescribed Responsibilities.
Confirm the person is fit and proper (see below).
Complete Form A on Connect and attach the SoR.
Submit before the intended start date, allowing time for the FCA's assessment.

Fitness and propriety — a prerequisite, not a formality

Before you submit Form A, the firm must have satisfied itself that the individual is fit and proper to hold the role. Form A itself asks a series of questions covering the individual's honesty, integrity and reputation, competence and capability, and financial soundness — the three fitness elements the FCA assesses.

This means the fit-and-proper assessment has to happen before the application, not after. You will need to have run criminal record checks (for SMF applicants), obtained regulatory references covering the previous six years from past employers, and documented your assessment. Our fitness and propriety guide covers what a defensible assessment looks like, and the F&P Decision Tree walks through the specific tests. Any adverse information disclosed in a reference or a criminal record check has to be considered and addressed in the application — you cannot simply leave it out.

How long does approval take?

Once a complete Form A is submitted, the FCA has a statutory period to decide. For a straightforward application the FCA aims to decide within a matter of weeks, but the statutory maximum for determining a complete application is significant, and the clock only starts when the application is complete. Missing information, unanswered questions, or an inconsistent Statement of Responsibilities can stop the clock and reset the timeline.

The practical implications for a small firm:

Apply early. Do not leave the application until the week before the person is due to start. Build in a buffer.
Submit a complete application. Incomplete applications are the single biggest cause of delay. Answer every question, attach the SoR, and make sure the fitness declarations are consistent with what you actually assessed.
Respond promptly to FCA queries. If the FCA comes back with questions, the assessment period can be paused until you respond.

If the person cannot legally start until approval is granted, the firm needs a plan for the interim — either the responsibilities sit with an existing approved Senior Manager, or the start date moves.

Common mistakes small firms make with Form A

1. Applying after the person has started. The pre-approval rule is absolute for Senior Managers. Appointing first and applying later is a breach.

2. Submitting Form A without a Statement of Responsibilities. The SoR is not optional and the application is incomplete without it.

3. Treating the fit-and-proper questions as a box-tick. Form A's honesty, competence and financial-soundness questions must reflect an assessment you have actually carried out and can evidence. Regulatory references and criminal record checks feed directly into these answers.

4. Inconsistent responsibilities across the firm. If two Senior Managers' Statements of Responsibilities overlap without explanation, or a Prescribed Responsibility is unallocated, the FCA will query it — and the clock stops.

5. Forgetting Form C on the way out. When a Senior Manager leaves or ceases the function, you have ten business days to submit Form C. This is easy to miss during a busy leaver process.

Where Form A fits in the wider SMCR picture

Form A is the approval mechanism for the top tier of the SMCR — the Senior Managers. Below them sit certified staff, who do not need FCA approval but must be certified by the firm as fit and proper, and whose details appear on the FCA Directory. If you are mapping out who at your firm needs what, the SMCR plain-English guide covers how the three tiers fit together, and our full guide to the FCA senior management functions sets out the complete function list.

Getting Form A right is part of the same discipline that the FCA has scrutinised more closely since 1 September 2026, when the extended non-financial misconduct rules took effect. A firm that can show clean, current approvals and Statements of Responsibilities is a firm that has its SMCR housekeeping in order.

Summary

Form A is the FCA application to approve an individual for one or more Senior Management Functions, submitted via Connect.
It must be submitted before the person starts the SMF role, with a Statement of Responsibilities attached.
The individual must be assessed as fit and proper first — criminal record checks and six-year regulatory references feed the application.
The FCA's assessment clock only starts on a complete application, so apply early and answer everything.
Use Form C (not Form A) within ten business days when a Senior Manager leaves (SUP 10C.14.5R).

Last reviewed: 3 September 2026. This guide explains the FCA's Form A application process for small regulated firms. It is general information about the Senior Managers and Certification Regime, not regulatory or legal advice, and it does not describe a ConductLog product feature — ConductLog is validating demand for a tool that helps small FCA-regulated firms handle conduct and misconduct processes. For your firm's specific obligations, check the FCA Handbook and consider professional advice.