UK Financial Services and Markets Bill Targets SM&CR, AR Regime Overhaul for Investment Managers
UK investment managers and advisers must prepare for sweeping FSMA reforms reshaping senior-manager accountability, appointed-representative oversight, AML supervision, and overseas recognition rules.
The Financial Services and Markets Bill, introduced in the House of Lords on 19 May 2026, would overhaul UK financial-services regulation under the government's Financial Services Growth and Competitiveness Strategy. For investment managers, the most consequential changes include: (i) streamlining the Senior Managers and Certification Regime by removing pre-approval requirements for certain senior management functions and repealing the statutory certification regime, with substance retained via FCA/PRA rulebooks; (ii) bringing appointed representatives within the SM&CR and tightening the AR regime; (iii) consolidating AML/CTF supervision under the FCA; (iv) introducing a provisional licences authorisation regime; and (v) creating new overseas recognition regimes. In-house counsel at UK-authorised managers should map current SM&CR and AR structures against the proposed reforms, prepare for AR onboarding and oversight changes, and monitor parliamentary progress ahead of likely enactment later this year.