FCA Statement of Responsibilities: Worked Examples for Small Regulated Firms

Every senior manager at an FCA-regulated firm needs a Statement of Responsibilities (SoR). At a large bank that is a substantial document drafted by a dedicated team. At a five-person IFA where one person holds three or four Senior Management Functions, it is often a single page — but it still has to be done, kept current, and resubmitted when things change.

This guide covers what an SoR actually has to contain, the rules that govern it, how to draft one at a small solo-regulated firm, when you must resubmit it to the FCA, and a worked example for a sole principal. 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 how the regime is structured, our SMCR plain-English guide is the pillar. For what SMCR compliance actually requires day-to-day, see our SMCR for small firms guide.

What is a Statement of Responsibilities?

A Statement of Responsibilities is a document that sets out, for one named Senior Manager, the aspects of the firm's affairs that individual is responsible for. It is personal to the individual and the SMF(s) they hold. The rules and guidance governing SoRs sit in SUP 10C.11 of the FCA Handbook, with the FCA's standard SoR form available through SUP 10C.

The SoR's job is simple: it should clearly show what the senior manager is responsible for and how that fits into the firm's overall governance. If something goes wrong in an area of the business, the FCA should be able to look at the SoRs and see who was accountable for it. That accountability link is the entire point of the Senior Managers Regime.

A SoR is not the same as a job description. A job description describes a role; a SoR allocates regulatory accountability. The two often overlap, but the SoR is the document the FCA relies on when deciding who was responsible for what.

Statement of Responsibilities vs prescribed responsibilities vs the responsibilities map

Three SMCR documents get confused with each other. They are distinct:

Statement of Responsibilities (SoR) — one per Senior Manager. What that individual is accountable for. Governed by SUP 10C.11.
Prescribed responsibilities — a defined list of specific responsibilities the FCA requires firms (other than Limited Scope firms) to allocate to Senior Managers. Governed by SYSC 24. Each prescribed responsibility a firm has must appear in the SoR of whichever SMF holds it. Our prescribed responsibilities guide covers the full list and how to allocate them.
Management responsibilities map — a single firm-wide document showing how all responsibilities fit together with no gaps. Only Enhanced firms are required to maintain one (SYSC 25). Core and Limited Scope firms do not need a formal map, though a simple one is good practice.

For most small firms — which are Core SMCR firms — that means: a SoR for each SMF holder, the firm's applicable prescribed responsibilities allocated into those SoRs, and no formal responsibilities map required.

Which Senior Management Functions does a small firm have?

A Senior Management Function (SMF) is a role that requires FCA pre-approval before the individual can perform it. The firm applies, the FCA assesses fitness and propriety, and the individual cannot start the role until approved.

Most small Core firms need only a handful:

SMF1 (Chief Executive) — the most senior executive. At a sole-principal firm, this is usually the principal.
SMF3 (Executive Director) — where there are other directors.
SMF16 (Compliance Oversight) — responsible for the compliance function.
SMF17 (Money Laundering Reporting Officer) — the MLRO.
SMF9 (Chair) — only where the firm has a designated board chair.

At a genuinely small firm, one person frequently holds SMF1 + SMF16 + SMF17 simultaneously. That is permitted — but it means that person's SoR has to capture all three sets of responsibilities clearly, and the firm should be able to explain why concentrating those roles in one individual is appropriate and managed.

What goes in a Statement of Responsibilities?

A SoR should set out, for the named individual:

The SMF(s) the person holds — listed by code and description.
The prescribed responsibilities allocated to them — each one the firm has to allocate (see the prescribed responsibilities list) that this person holds.
Any other responsibilities — significant business areas, activities, or functions the individual is responsible for beyond the prescribed list.
Sharing or division arrangements — where a responsibility is shared with or divided between Senior Managers, the SoR should explain how.

The guiding principle in SUP 10C.11 is clarity: someone reading the SoR should understand what the person is responsible for without needing to cross-reference a stack of other documents. Allocating a responsibility in a SoR does not reduce or alter the scope of any prescribed responsibility — you cannot narrow a regulatory obligation by wording it carefully.

Worked example: sole principal holding SMF1, SMF16 and SMF17

Consider "Sarah", the sole principal of a four-person directly-authorised mortgage and protection firm. She holds SMF1 (Chief Executive), SMF16 (Compliance Oversight), and SMF17 (MLRO). Her SoR would, in plain terms, cover:

Senior Management Functions held: SMF1, SMF16, SMF17.

Prescribed responsibilities allocated (illustrative — the firm confirms its applicable set against SYSC 24 Annex 1):

Responsibility for the firm's performance of its obligations under the Senior Managers Regime.
Responsibility for the firm's performance of its obligations under the Certification Regime.
Responsibility for the firm's performance of its obligations in respect of notifications and training on the Conduct Rules.
Responsibility for the firm's compliance function and its policies and procedures for countering financial crime, including the MLRO function.

Other responsibilities: Overall responsibility for the firm's mortgage and protection advice business; oversight of the firm's appointed representatives (if any); responsibility for the firm's regulatory permissions and reporting.

In practice this is one page. The complexity of the SoR matches the complexity of the firm — but every responsibility the firm carries has to land in someone's SoR, and at a sole-principal firm that someone is usually the principal.

When do you have to resubmit a Statement of Responsibilities?

This is where small firms most often slip. A SoR is not a one-time document. You must keep it up to date and resubmit it to the FCA whenever there is a significant change to a Senior Manager's responsibilities. Triggers include:

A new prescribed responsibility being allocated to, or removed from, the individual.
The individual taking on or giving up an SMF.
A material change in the business areas the individual is responsible for.
A reorganisation that shifts accountability between Senior Managers.

You also submit a SoR when you apply for a new Senior Manager to be approved. The SoR is part of the approval application, not a separate filing.

PS25/23 is a relevant trigger to review SoRs. From 1 September 2026, the expanded scope on non-financial misconduct changes how some conduct-related responsibilities are framed; firms should check whether any SoR wording needs updating as part of their PS25/23 readiness work. Our PS25/23 compliance checklist walks through the wider programme.

Common Statement of Responsibilities mistakes at small firms

1. Treating it as a job description. The SoR allocates regulatory accountability. A vague "responsible for running the business" line does not show the FCA who was accountable for a specific failing.

2. Letting it go stale. A SoR that still reflects the firm as it was two years ago is a problem the moment something goes wrong. Review SoRs at least annually and on every significant change.

3. Gaps in prescribed responsibilities. Every prescribed responsibility the firm has to allocate must appear in someone's SoR. An unallocated prescribed responsibility is a compliance failure, not an oversight.

4. Forgetting to resubmit. Updating the SoR internally but not resubmitting it to the FCA when required leaves the regulator holding an out-of-date document.

Where to start

Confirm which SMFs exist at the firm and who holds each. Use the COCON Self-Assessment to confirm staff are correctly classified across SMF / certified / conduct rules staff.
Confirm the firm's applicable prescribed responsibilities against SYSC 24 Annex 1, then allocate each into the relevant SoR — see our prescribed responsibilities guide.
Draft or refresh a SoR for each SMF holder using the FCA's standard form (SUP 10C).
Resubmit any SoR that has materially changed since it was last filed.

ConductLog is building tooling to make keeping SoRs, prescribed-responsibility allocations, and conduct-rule records current at a small firm a single connected workflow rather than four disconnected documents. 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.