SM&CR Training Evidence

The Senior Managers and Certification Regime (SM&CR) requires firms to maintain robust training evidence for role-specific competencies. This includes demonstrating that senior managers and certified staff have the necessary skills and knowledge to perform their roles effectively. The regulatory challenge lies in ensuring that training is not only delivered but also adequately documented and aligned with the FCA's expectations for competency and accountability.

Firms must produce evidence of role-specific training and continuous professional development (CPD) records. This evidence should clearly link training activities to the competencies required for specific roles under SM&CR. It is essential that firms maintain accurate records that can be readily accessed and reviewed by regulators to demonstrate compliance.

Current approaches, such as using spreadsheets, email trails, or shared folders, often lead to governance gaps. These methods can result in incomplete or inconsistent records, making it difficult to provide repeatable evidence of training and competency. Without a structured approach, firms may struggle to demonstrate accountability and may face challenges during regulatory reviews.

To strengthen their position, firms should implement a systematic approach to tracking and documenting SM&CR training evidence. This includes assigning clear ownership of training records, ensuring board visibility, and maintaining an escalation process for addressing any deficiencies. A centralised system can help streamline the process and provide a clear audit trail.

Senior managers are accountable for ensuring that their teams are competent and that training records are up-to-date. They must be able to demonstrate that appropriate training has been delivered and that the necessary competencies are maintained. This accountability is a key component of the SM&CR framework and requires a proactive approach to training governance.

Escalation records and repeatable evidence are crucial for demonstrating compliance with SM&CR requirements. Firms should have a clear process for escalating any issues related to training deficiencies or gaps in competency evidence. This ensures that any potential risks are addressed promptly and that the firm remains compliant with regulatory expectations.

RegNexus offers a solution through its RegAcademy platform, which provides a structured framework for managing SM&CR training evidence. This platform facilitates governance, evidence collection, and reporting, helping firms maintain readiness for regulatory scrutiny without the pitfalls of traditional methods.