The PRA and FCA want fewer pre-approvals. CEOs, CFOs and chairs would still need one.

The live UK compliance document this week is not a central-bank rate. It is a pair of consultations the Prudential Regulation Authority and the Financial Conduct Authority opened on 22 October 2026, to streamline the Senior Managers and Certification Regime. The Bank of England published the announcement. Comments are open until 22 January. Policy is expected in 2027. Some of the reforms need legislation, and the regulators said they are consulting now so they can implement quickly once that legislation exists.

The regime is ten years old in the announcement’s telling. It was built so senior decision-makers could be held accountable. The proposal is to keep that and to take administrative steps off roles the regulators no longer want to pre-approve.

Who would still need a yes before they start#

Regulator pre-approval would be removed for a range of functions, and the announcement names chief actuaries and the chairs of risk and audit committees. Firms would notify those appointments instead, and would remain responsible for fitness and propriety. The regulators would still be able to require pre-approval of an otherwise notified role in a high-risk case.

CEOs, CFOs and chairs would continue to need pre-approval, including a fit-and-proper test, before appointment. People who no longer need pre-approval would, the announcement says, be held to the same accountability as before. Firms would remain responsible for competence, suitability and conduct.

That split is the whole reform. A compliance programme that treats “SM&CR is being simplified” as “senior managers no longer need approval” has dropped the sentence about CEOs, CFOs and chairs.

The certification population, and the money figure#

The certification regime, and the annual checks and Financial Services Register entries that go with it, would be removed for around 139,000 individuals below senior-manager level. The conduct-rule breach reporting threshold would be raised for most staff below that level, and conduct-rule training would be streamlined, so firms aim the process at more serious misconduct.

The Bank of England said the changes are expected to save firms around £2 billion over ten years. The notes to editors are more specific and should not be rounded into that headline. PRA SM&CR pre-approvals would fall by 43%, and the overall burden of the PRA regime would be halved. For FCA enhanced solo-regulated firms, where fewer senior-manager functions apply, about 15% of applications would move to notification, two senior-manager-function roles would be removed, and a further 19% would be saved. The PRA’s latest quarterly data showed 98% of applications determined inside the proposed new two-month statutory deadline, against 98.3% in the FCA’s most recent quarterly metrics.

Katharine Braddick, Deputy Governor for Prudential Regulation and chief executive of the PRA, said the regime stays essential, that checks remain for the most important roles, and that the point of the rest is time and flexibility. Sarah Pritchard, deputy chief executive, said the same standards could be kept with a more streamlined regime. Both sentences are the case the regulators are putting. The consultation is the place that case can be answered. It is not yet a rule.

April 2026 is the first phase in the notes: longer timelines after unexpected or temporary senior-manager changes, removal of duplicate certification for overlapping functions, and a 30% rise in enhanced-firm thresholds. Phase two is the document that is open now.

A firm that maps roles this week should map them against the consultation, not against a 2027 rulebook. The pre-approval list that still includes the chief executive, the finance director and the chair is the list that has not moved.

This is a briefing on a published consultation. It is not legal advice and not a statement of the final rule.