Applying for a Senior Management Function (Form A): A Practical Guide

What a Senior Management Function is and why approval comes first

A Senior Management Function is a type of controlled function held by a firm's most senior people, those who carry key responsibilities for running the firm. The FCA is clear on the timing: anyone who performs an SMF needs to be approved before they can start their role. This is not a courtesy step. It is a legal control on who runs regulated businesses.

The statutory foundation sits in the Financial Services and Markets Act 2000. Section 59 requires an authorised person to take reasonable care to ensure that no person performs a controlled function under an arrangement entered into by the firm unless that person is acting in accordance with an approval given by the appropriate regulator. In plain terms, letting someone perform an SMF without FCA approval breaches the Act.

Which SMFs a firm needs depends on its firm type under the regime. Common examples the FCA lists include the chief executive officer, the chair of the governing body, the chief risk officer, an executive director, compliance oversight, and the money laundering reporting officer. Each SMF holder must have responsibilities clearly allocated to them, which is why the Statement of Responsibilities is central to every application.

Form A: the application to perform an SMF

Form A is the application form used to request FCA approval for an individual to perform a controlled function, including a Senior Management Function. It comes in two versions. The long version is required where the candidate has not previously held a senior management or controlled function, has not been approved in the last six months, or where there have been changes to their fitness and propriety since their last approval. The short version is used for a previously approved candidate with no material changes.

The firm submits Form A, not the individual. An appropriate person completes the form on behalf of the firm and the candidate, and the FCA advises that the candidate should check the form before it is submitted. The form must include the candidate declaration and a Statement of Responsibilities for the role, along with supporting documents such as explanations for any adverse information.

There is a fee for standalone long Form A applications, which the FCA sets as a category 1 fee. There is no separate charge when a Form A is submitted alongside an authorisation application, a variation of permission, or an appointed representative registration. Firms should confirm the current fee amount on the FCA's fees pages before submitting, since fee levels change over time.

If an approved person needs to move between controlled functions internally, a different form applies. Form E is used for internal transfers where an approved person needs to cease one or more controlled functions and apply for approval for a different one.

Submitting through Connect: the steps

All SMF applications are made online through the FCA's Connect system. Firms sign in to My FCA using their existing credentials, then complete the relevant form. Preparing the supporting documents before you start makes the online process far smoother, because Form A asks for detail that is difficult to assemble at the last minute.

The following sequence reflects how the FCA describes the process. Build in time for the criminal records check and the Statement of Responsibilities in particular, as these are the two items most likely to hold up an otherwise ready application.

The fit and proper test: honesty, competence and financial soundness

The heart of the FCA's decision is whether the candidate is fit and proper to perform the role. Under section 61 of the Financial Services and Markets Act 2000, the FCA may grant approval only if it is satisfied that the person is a fit and proper person to perform the function, or, for senior management functions, that this condition will be met if approval is granted subject to conditions.

The FCA's Fitness and Propriety guidance sets out the main elements it considers: honesty, integrity and reputation; competence and capability; and financial soundness. Each is assessed in its own right, and an adverse finding under any one of them can call a candidate's suitability into question.

Honesty, integrity and reputation covers matters such as criminal history, adverse findings in civil or regulatory proceedings, and any breach of regulatory requirements. Competence and capability looks at whether the individual has demonstrated the relevant experience and has the time available to perform the function. Financial soundness examines matters such as judgment debts, creditor arrangements and bankruptcy, though the FCA notes that being of limited financial means will not, in itself, make someone unsuitable.

Fitness and propriety is not only assessed at the point of application. Firms owe an ongoing duty, and the FCA's guidance makes clear that these assessments apply to individuals who are SMFs or who meet the criteria for a Certification Function, with re-assessment where a material change makes it necessary.

What the application must contain

A complete Form A brings together several distinct pieces of evidence. Getting each one right before submission reduces the chance that the FCA has to stop the clock to ask for more information. The table below summarises the core requirements and where they come from.

The Statement of Responsibilities deserves particular attention. It is required by rule, not just as good practice. SUP 10C.11.3D provides that an application for FCA approval of an FCA-designated senior management function must be accompanied by a Statement of Responsibilities. It is defined in section 60(2A) of the Act as setting out the aspects of the firm's affairs the person will be responsible for managing, and the FCA expects it to be practical, useable, without unnecessary detail, and succinct and clear.

Criminal records checks and regulatory references

Most firms should undertake a criminal records check as part of each SMF application, so the firm can confirm the candidate has given accurate and complete information. The check is run through the Disclosure and Barring Service in England and Wales, Disclosure Scotland in Scotland, or AccessNI in Northern Ireland, and the firm needs to register with the relevant agency to obtain it.

Timing matters here. The FCA asks for the date of the criminal records check and details of any records shown. If the check was completed more than six months before the application, the firm needs to explain how it verified the candidate's fitness. If you have not obtained a check when you apply, the application may be rejected unless the candidate is a sole trader or an exemption applies under SUP 10C.10.16.

Regulatory references are the other external evidence the FCA weighs. The Fitness and Propriety guidance treats references that disclose misconduct or relevant concerns, and that are produced in a timely manner, as a positive indicator. References that fail to provide the necessary information, or that do not arrive promptly, count against a smooth assessment. Requesting references early, and chasing them, is one of the simplest ways to keep an application moving.

How the FCA assesses and the three month decision period

Once a complete Form A is submitted, the FCA applies a risk based approach, weighing the candidate's background, the role, the firm's size and history, and market risks, and it assesses each application on its own merits. It may invite a candidate to an interview where it has questions about fitness or the significance of the role, giving advance notice of the topics.

The timing is set in statute. Section 61 of the Financial Services and Markets Act 2000 gives the FCA a period for consideration, which in the standard case is the period of three months beginning with the date on which the regulator receives the application. The FCA states the same duty plainly: it must decide on an application within three months of receiving it. Where an application is submitted with a Part 4A permission application, the relevant period can align with the timetable for that permission.

That three month period is a statutory ceiling, not a service target, and it applies to a complete application. If the FCA needs more information, or decides to interview the candidate, it may stop the clock, pausing the application until the information is received or the interview has taken place. Submitting a clean, complete Form A with a clear Statement of Responsibilities, a current criminal records check and references already in hand is the most reliable way to avoid the clock stopping.

Conclusion

A Form A application is the gateway to a Senior Management Function, and the FCA will not let a candidate start until that approval is granted. The application is more than a form. It is a package: the candidate declaration, a clear Statement of Responsibilities required by SUP 10C.11.3D, evidence of fitness and propriety across honesty, competence and financial soundness, a criminal records check, and regulatory references. Assembling these before you open Connect is what turns a three month statutory ceiling into a routine, uneventful approval.

The firms that move fastest treat the Statement of Responsibilities and the criminal records check as the pacing items, request references early, and answer the fitness and propriety questions fully rather than leaving gaps for the FCA to chase. If you are preparing an SMF application, or building your senior manager governance from scratch, Nasara Connect can help you structure the evidence and get the submission right first time. Explore our authorisation support or book a demo to see how we streamline Form A.

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