Certification Staff and the Financial Services Register

Nearly nine months ago you were required to implement the requirements of the FCA’s new Senior Managers & Certification regime. There is no doubt that a lot has happened in the interim.

It is probably fair to say that the regulator’s recent Dear CEO letter – sent to all personal lines and commercial insurance intermediaries – and their follow-up to their Financial Resilience questionnaire – represents continued evidence that the regulatory wheel continues to turn and indeed, appears to be building momentum.

Whilst I do know that colleagues are preparing some guidance in relation to the aforementioned letter (so watch this space), I wanted to remind you of the regulator’s plans to publish and maintain a directory of certificated persons on the Financial Services Register.

In their March 2019 policy statement, the FCA stated that the purpose of the Directory is to:

  • “make information public on additional individuals carrying out specific roles in UK financial services (including certain roles we do not approve such as financial advisers, traders, portfolio managers and additional directors
  • present information on these individuals and the Senior Managers we continue to approve in a way that is more accessible and user friendly
  • enable users to find information on these individuals”

The aim of the Directory is to “empower customers and other stakeholders to make sure they only deal with SMFs or those who an authorised firm has assessed as fit and proper, or otherwise suitable and those who have appropriate qualifications”.

The initial deadline to upload to the Directory was scheduled to be 12/12/2020 however the current pandemic has caused the FCA to delay the submission of information about directory persons to 31/03/2021. Page 5 of the above policy statement sets out a list of information that will appear publicly on the register.


To be clear, a directory person or in other words, a person whose information you must submit to the FCA will be:

  • all certified staff (those holding a certification function under the SM&CR) – which you must have identified by 09/12/2019
  • directors who are not performing Senior Manager Functions (SMFs) – both executive and non-executive
  • other individuals who are sole traders or ARs (including those within ARs) where they are undertaking business with clients and require a qualification to do so

To submit directory person data successfully, you need to:

  • Capture
  • Upload
  • Submit

Submission will be via the FCA’s CONNECT system. You cannot submit data without this. Please refer to the FCA’s user guide. Their Q & A document also contains useful information. You can read it here.

Any questions please refer to your RWA Regional Business Manager.

About the author

Bruce has worked in financial services for the whole of his professional life, including 11 years as a Compliance Director of a US owned Independent Financial Advisory and Wealth Management business. At RWA, Bruce leads the Audit and Conduct Risk department from our Manchester office. He is RWA's lead consultant to the Guernsey Financial Services Commission (GFSC).

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