Statements of Responsibilities: How to Write One That Holds Up

What a Statement of Responsibilities actually is

A Statement of Responsibilities is defined in law and in the Handbook. Section 60(2A) of FSMA requires that when a firm applies for approval for a person to perform a designated senior management function, the application must contain a statement setting out the aspects of the firm's affairs that the person will be responsible for managing. SUP 10C.11.1G confirms that this statement is the Statement of Responsibilities.

The FCA describes it in FG19/2 as a single document that every Senior Manager needs, clearly setting out their roles and responsibilities under the ultimate accountability of the firm's governing body. Its purpose is to make clear what the Senior Manager is accountable for. Crucially, it is not a job profile: the FCA states a SoR should not describe the competencies and skills required for the role or how the responsibilities should be discharged, only what the role holder is accountable for.

The SoR is captured on the FCA's prescribed form, which every application for an SMF approval must accompany. The form is divided into sections for Prescribed Responsibilities, Overall Responsibilities and any other responsibilities specific to the role, so the structure of the document is set by the regulator rather than left to the firm.

Nasara Connect's control platform helps firms build, version and evidence each SoR against the exact Handbook sections, so the accountability picture stays audit-ready rather than sitting in a forgotten Word file.

Who needs one, and how it fits the SM&CR

Every SMF holder needs a Statement of Responsibilities, without exception. That applies across all three categories of solo-regulated firm. Limited Scope firms are exempt from some baseline requirements and typically have fewer SMFs, but the SMFs they do have still need a SoR. Core firms comply with the full baseline requirements. Enhanced firms, a small number whose size, complexity and potential impact on consumers or markets warrant more attention, face additional requirements on top.

SUP 10C.11.20R states that a firm must, at all times, have a complete set of current Statements of Responsibilities for all its SMF managers. This is a standing obligation, not a one-off filing. The guidance at SUP 10C.11.21G makes clear that current means the statements reflect all significant changes to a Senior Manager's responsibilities, even where an updated version has not yet been submitted to the regulator.

The document also has to sit inside the firm's wider governance picture. SUP 10C.11.23G requires that a SoR be consistent with the firm's Management Responsibilities Map, where the firm is required to have one. Enhanced firms must maintain such a map; Core and Limited Scope firms generally do not, but their SoRs must still form a coherent, gap-free whole.

Prescribed Responsibilities and how they slot in

Prescribed Responsibilities are specific accountabilities that the FCA requires firms to allocate to named Senior Managers. SYSC 24.2.1R states that a firm must allocate each of the FCA-prescribed senior management responsibilities that apply to it to one or more SMF managers. The full list sits in the table at SYSC 24.2.6R and covers areas such as performance of the firm's obligations under the Senior Managers Regime and the Certification Regime, financial crime policies and procedures, the whistleblowers' champion role and, where relevant, CASS compliance.

The specific Prescribed Responsibilities that need allocating depend on the firm's activities and, for solo-regulated firms, whether it is a Core or Enhanced firm. Limited Scope firms do not have Prescribed Responsibilities at all. Each one that applies should generally be given to the most senior person responsible for that area, in line with the guidance in SYSC 24.

Once allocated, every Prescribed Responsibility held by a Senior Manager must appear in that person's SoR. SUP 10C.11.26G makes the point that the allocation of responsibilities under a SoR should not reduce or alter the scope of any applicable Prescribed Responsibility. In other words, you cannot narrow a Prescribed Responsibility by the way you word the statement; the full regulatory scope travels with it.

How to write a Statement of Responsibilities

The FCA's drafting expectations are concrete. SUP 10C.11.25G says a SoR should be practical and usable by the FCA, succinct and clear, and free of unnecessary detail. SUP 10C.11.24G adds that it must be complete in itself and not refer to documents that do not form part of it. FG19/2 reinforces this: a SoR needs to be self-contained and not refer to other documents.

A useful test from FG19/2 is to ask whether someone who understands your type of business, but does not know how your firm is organised, could read the SoR and understand what the individual is accountable for. If the answer is no, the statement is not doing its job. Remember it captures what the person is accountable for, not the skills they bring or the way they will carry the work out.

The steps below follow the FCA form and the Handbook order. Work through them for each Senior Manager, then read the firm's full set of SoRs together to confirm there are no gaps or unexplained overlaps.

When to submit and resubmit

The first submission point is fixed by rule. SUP 10C.11.3D requires that an application for the FCA's approval to perform an FCA-designated senior management function must be accompanied by a Statement of Responsibilities. The SoR is therefore part of the approval application, not an afterthought.

After approval, the trigger for a new version is change. SUP 10C.11.5G expects a firm to provide a revised SoR whenever there has been a significant change in the responsibilities of an approved SMF manager. Cosmetic edits do not require refiling, but a genuine shift in what someone is accountable for does. Because SUP 10C.11.20R requires the firm to hold a complete and current set at all times, the internal document should be updated as soon as the change takes effect, even before it is submitted.

The Handbook does allow some batching of submissions. SUP 10C.11.6C permits a firm to submit revised statements once in every six-month period rather than immediately for each change, with flexibility for changes that fall near the end of a period. This eases the administrative load, but it does not relax the underlying duty to keep the live document accurate.

Do not discard superseded versions. SUP 10C.11.22G treats past versions of a SoR as an important part of the firm's records and a resource for the FCA when supervising the firm, so retain a full version history.

Common FCA criticisms, and how to avoid them

The most frequent problem is a gap: an activity or risk that no Senior Manager clearly owns. SUP 10C.11.27G expects the set of statements to demonstrate that there are no gaps in the allocation of responsibilities among the firm's SMF managers, and says they should be interpreted so as to avoid any gaps. In its worked examples, the FCA flags cases where it is not clear who is responsible for countering the risk that the firm might be used to further financial crime, precisely the kind of unowned area supervisors probe.

The mirror image is unexplained overlap. Sharing a responsibility is permitted, but it must be justified and precisely defined. FG19/2 criticises a firm where all directors shared the Prescribed Responsibilities because they took collective responsibility, noting that this is not an appropriate reason to share under the rules, that individual accountability is lost, and that it becomes unclear what each person is actually responsible for. Where sharing is genuine, SUP 10C.11.32G requires full details of the arrangement, including the names and FCA or PRA Individual Reference Numbers of the other people, recorded the same way in each person's statement.

The third failing is vagueness. Statements that read like job descriptions, lean on jargon, or cross-refer to other policies fall short of the succinct, clear, self-contained standard. The fix is disciplined drafting: one accountability per line, plain language, no external references, and a final read-through against the whole-firm picture. Firms building an SM&CR framework from scratch, for example when applying for authorisation, can map responsibilities cleanly from day one using Nasara Connect's authorisation tools.

Conclusion

A Statement of Responsibilities is deceptively simple: a single, self-contained document that says what one Senior Manager is accountable for. Done well, it protects the individual by defining the boundaries of their Duty of Responsibility and protects the firm by proving to the FCA that every regulated activity has a clear owner. Done poorly, with gaps, blanket sharing or job-description padding, it invites supervisory scrutiny and weakens accountability exactly where it matters most.

Treat the SoR as a living record. Draft it against SUP 10C.11, allocate Prescribed Responsibilities per SYSC 24, keep it consistent with your Management Responsibilities Map where one is required, submit it with each approval application, revise it on every significant change, and retain the full version history. Get that discipline right and the document becomes an asset rather than a liability.

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