FCA Hiring Checklist: Pre-Appointment Screening for SMCR Roles

This checklist covers the pre-appointment due diligence steps required by FCA-regulated firms under the Senior Managers & Certification Regime (SMCR). Use it alongside your firm's own fitness and propriety policy and FCA regulatory reference process.

Checklist 1 — Senior Management Function (SMF) holders

Required before the individual commences the SMF role. FCA pre-approval must be obtained before the individual can act in the function.

• Identity verification — document scan and facial match to confirm identity
• Right to Work — legal right to work in the UK confirmed
• FCA Individual check — current FCA registration status, controlled functions held, regulatory notices and prohibitions
• PEPs & Sanctions screening — global PEPs lists and sanctions databases (UK HMT, UN, EU, OFAC)
• Adverse media screening — open-source press, court records, and regulatory enforcement databases
• Credit history (5 years) — CCJs, insolvency, defaults, arrears — financial soundness assessment
• Work history (5 years verified) — confirmed employment history, direct employer verification
• Address history (5 years) — verified residential address history
• Directorship history — prior directorships and disqualifications via Companies House
• Regulatory reference obtained — formal reference from each regulated employer in the past 6 years (FCA SYSC 22) — managed separately from screening
• Fitness and propriety assessment documented — formal internal assessment against FIT criteria: honesty/integrity/reputation, competence/capability, financial soundness
• FCA pre-approval application submitted — via Connect before the individual commences the SMF role

Checklist 2 — Certification Function staff

Required before the individual starts in a Certification Function role. No FCA pre-approval needed, but the firm must certify them as fit and proper.

• Identity verification — document scan and facial match
• Right to Work — legal right to work in the UK confirmed
• FCA Individual check — register status and regulatory history (particularly important if the individual has previously held a regulated role)
• PEPs & Sanctions screening — global PEPs lists and sanctions databases
• Adverse media screening — open-source reputation check
• Credit history (5 years) — for roles with financial responsibility or access to client assets
• Work history (5 years verified) — confirmed employment history
• Address history (5 years) — verified residential address history
• Directorship history — prior corporate roles and disqualifications
• Fitness and propriety assessment documented — internal assessment against FIT criteria
• Written certificate issued — firm certifies the individual as fit and proper before they commence the role

Checklist 3 — Annual re-certification (Certification Function staff)

Must be completed at least once per calendar year for all Certification Function staff.

• PEPs & Sanctions re-screen — status can change; re-screening confirms no new sanctions or PEP designations
• Adverse media re-screen — check for any negative coverage since last certification
• FCA Individual check refresh — confirm no new regulatory notices or prohibition orders
• Credit history refresh — for roles with financial responsibility (risk-based, not always required annually)
• Internal conduct review — review of any internal disciplinary matters, complaints, or conduct issues in the year
• Fitness and propriety re-assessment documented — updated assessment against FIT criteria
• Written re-certification issued (or declined) — firm issues updated certificate or notifies FCA if individual no longer fit and proper

Checklist 4 — Ongoing monitoring

Between annual re-certifications, firms should consider:

• PEPs & Sanctions monitoring — automated monitoring for newly sanctioned individuals (particularly for firms with large regulated workforces)
• Adverse media monitoring — alerts for significant negative coverage of named individuals
• Regulatory notice monitoring — FCA/PRA enforcement actions, public censures, and prohibition orders published on the FCA Register
• Internal trigger reviews — any significant conduct event, disciplinary proceeding, or customer complaint should prompt an out-of-cycle fitness and propriety review

Record-keeping checklist

For each SMF holder and Certified Person, maintain the following on file:

• All check results with timestamps and provider details
• Fitness and propriety assessment (initial appointment and each annual re-certification)
• Written certification records (date issued, issuing officer)
• Regulatory references obtained and any adverse information disclosed
• FCA application submissions and approval decisions (SMF holders)
• Any notifications made to the FCA (e.g. individual ceasing to be fit and proper)

InfoVetted covers all screening checks in this checklist in a single platform. Book a demo to see how the SMCR package works in practice.