FCA Prescribed Responsibilities: The Core-Firm List and How to Allocate Them

Prescribed responsibilities are one of the parts of SMCR that small firms most often get wrong — not because they are hard, but because firms either over-complicate them (copying an Enhanced-firm list they don't need) or miss one entirely (leaving a responsibility unallocated). At a Core firm the list is short, the allocation is usually obvious, and getting it right is mostly a matter of knowing which responsibilities actually apply to you.

This guide covers what prescribed responsibilities are, the specific list that applies to Core solo-regulated firms, what each one means in practice, who to allocate them to, and the small-firm carve-outs in the rules. It is written for compliance officers and principals at IFAs, mortgage brokers, insurance brokers, and small wealth managers with 1–50 staff.

For the foundational view of the regime, our SMCR plain-English guide is the pillar. For how prescribed responsibilities feed into each Senior Manager's accountability document, see our Statement of Responsibilities guide.

What are prescribed responsibilities?

A prescribed responsibility is a specific responsibility the FCA requires firms to allocate to a Senior Manager. The list is set by the FCA, not by the firm — you do not invent your own. The rules sit in SYSC 24 of the FCA Handbook, with the allocation rules in SYSC 24.2 and the firm-type applicability in SYSC 24 Annex 1.

The purpose is to make sure certain critical responsibilities always have a named, FCA-approved owner. The firm must allocate each prescribed responsibility that applies to it to one or more SMF managers — and each one then appears in that manager's Statement of Responsibilities.

Prescribed responsibilities sit alongside, not instead of, a senior manager's other responsibilities. Allocating a prescribed responsibility to someone does not reduce or narrow its scope.

Which firms have prescribed responsibilities?

This is the key scoping question, and it depends on the firm's SMCR category:

Limited Scope firms — no prescribed responsibilities apply. Limited Scope firms (e.g. certain sole traders, some authorised professional firms, limited-permission consumer credit firms) are outside the prescribed-responsibility requirements entirely.
Core firms — a short, defined set applies (below). Most small directly-authorised firms are Core.
Enhanced firms — a longer list applies, including additional governance and risk responsibilities. Almost no small firms are Enhanced; the Enhanced threshold is set for larger or more complex businesses.

So the first step is to confirm your firm's category. If you are Limited Scope, prescribed responsibilities do not apply to you at all. If you are Core — which most small firms are — the list below is what matters.

The prescribed responsibilities for Core solo-regulated firms

A Core solo-regulated firm must allocate the following prescribed responsibilities. The lettering follows the FCA's references:

(a) — Senior Managers Regime obligations. Responsibility for the firm's performance of its obligations under the Senior Managers Regime, including the implementation and oversight of the regime.

(b) — Certification Regime obligations. Responsibility for the firm's performance of its obligations under the Certification Regime — the annual fitness-and-propriety certification of staff in certification functions.

(b-1) — Conduct Rules notifications and training. Responsibility for the firm's performance of its obligations in respect of notifications and training on the Conduct Rules — i.e. that conduct rules staff are trained and that breaches are notified to the FCA.

(d) — Financial crime. Responsibility for the firm's policies and procedures for countering the risk that the firm might be used to further financial crime. At most small firms this aligns with the MLRO (SMF17).

There is also one conditional prescribed responsibility:

(z) — CASS. Responsibility for the firm's compliance with the FCA's Client Assets Sourcebook (CASS). This applies only if the firm holds or controls client money or assets subject to CASS. Most small advice firms do not, so for them this responsibility does not apply.

That is the complete Core-firm picture: four prescribed responsibilities that always apply, plus the CASS one if the firm is subject to CASS. If your firm's adviser or consultant has handed you a list of fifteen prescribed responsibilities, they have given you the Enhanced-firm list — confirm your category before allocating anything you don't need.

Who should hold each prescribed responsibility?

The rule (SYSC 24.3) is that a prescribed responsibility should be allocated to the Senior Manager who is the most senior person responsible for that area. In practice, at a small Core firm:

(a) Senior Managers Regime → usually SMF1 (the principal / CEO).
(b) Certification Regime → usually SMF1 or SMF16 (Compliance Oversight).
(b-1) Conduct Rules notifications and training → usually SMF16 (Compliance Oversight).
(d) Financial crime → usually SMF17 (MLRO).
(z) CASS (if applicable) → whoever oversees the firm's client-asset arrangements.

At a sole-principal firm where one person holds SMF1 + SMF16 + SMF17, all of these can land with the same individual — which is permitted, provided the firm can explain why the concentration is appropriate.

The FCA recognises that strict allocation guidance may not be practical for a small, non-complex firm. SYSC 24.3 acknowledges that some of the allocation guidance that would otherwise apply may not be practical for a small non-complex firm — but the underlying obligation to allocate each applicable prescribed responsibility still stands. The carve-out is about how you document the allocation, not whether you have to do it.

Common prescribed-responsibility mistakes at small firms

1. Using the Enhanced-firm list. The single most common error. A Core firm copying an Enhanced list ends up allocating responsibilities that do not apply to it, creating accountability for things the regime never asked for.

2. Leaving one unallocated. Every applicable prescribed responsibility must be allocated to a Senior Manager and must appear in that person's Statement of Responsibilities. A gap is a compliance failure.

3. Allocating (z) CASS when you're not a CASS firm. Only allocate the CASS prescribed responsibility if the firm actually holds client money or assets subject to CASS. Allocating it when it doesn't apply is needless.

4. Not reflecting allocation in the SoR. Allocating a prescribed responsibility internally but not capturing it in the holder's Statement of Responsibilities breaks the audit trail the FCA relies on.

Where to start

Confirm your firm's SMCR category — Limited Scope (no PRs), Core (the list above), or Enhanced (longer list). Check against SYSC 24 Annex 1.
If Core, work through the four (or five, with CASS) prescribed responsibilities and confirm which apply.
Allocate each to the most senior person responsible for that area.
Record each allocation in the relevant Senior Manager's Statement of Responsibilities.
Use the COCON Self-Assessment to confirm your staff are correctly classified across the SMF, certified, and conduct rules staff tiers.

ConductLog is building tooling to keep prescribed-responsibility allocations, Statements of Responsibility, and conduct-rule records connected in one workflow at a small firm. Join the waitlist to hear when it launches.

References

This guide is for general information only and does not constitute legal or regulatory advice. Last reviewed: 4 June 2026.