Practical advisory support for FCA-regulated firms designing, implementing and enhancing SMCR and governance frameworks aligned with supervisory expectations. Cambitas advises regulated financial services organisations on governance structures that enable clear accountability, effective oversight and sustainable regulatory compliance.
SMCR & Governance Advisory
CAMBITAS
Strengthen Accountability and Governance with Confidence
The Regulatory Landscape
Why Governance Advisory Matters
- Clear governance structures enable senior leaders to understand precisely where accountability sits, reducing ambiguity in decision-making and supporting effective oversight across regulated activities.
- Regulators increasingly assess how governance operates in practice, meaning firms must be able to evidence responsibilities, escalation processes and board oversight through consistent documentation and behaviour.
- Well-designed governance frameworks strengthen organisational resilience by aligning leadership accountability, risk management and strategic decision-making, helping firms avoid reactive remediation and regulatory intervention.
Integrated SMCR & Governance Advisory
Our Services
Cambitas provides advisory support across the full lifecycle of SMCR implementation and governance enhancement.
Conduct Rules Implementation & Training
- Cambitas supports the rollout of Conduct Rules frameworks, including policy development, governance integration and training design for Senior Managers, certification staff and wider employees.
- The aim is to ensure conduct obligations are understood, embedded and supported by appropriate internal processes.
SMCR Implementation & Framework Design
- We support firms implementing the Senior Managers and Certification Regime for the first time or redesigning existing arrangements. This includes structuring governance models, identifying Senior Management Functions (SMFs), and establishing practical accountability frameworks aligned with FCA requirements.
- A well-designed SMCR framework provides clarity across leadership roles, reduces ambiguity in decision-making and strengthens regulatory credibility.
Senior Manager Responsibilities Mapping
- Cambitas assists firms in defining and allocating responsibilities across Senior Managers in a clear and defensible way.
- We help ensure responsibilities reflect the firm's operating model, governance structure and regulatory obligations, while avoiding overlaps or gaps that can create accountability risks.
Statements of Responsibilities & Management Responsibilities Maps
- We draft and refine Statements of Responsibilities (SoRs) and Management Responsibilities Maps (MRMs) that accurately reflect how a firm is governed in practice.
- These documents are often central to FCA supervisory assessments and must demonstrate clear allocation of responsibilities and decision-making authority across the organisation.
Certification Regime Design & Oversight
- We advise firms on building effective Certification Regime frameworks for staff performing significant harm functions.
- Our work includes defining certification populations, designing annual assessment processes and developing documentation that allows firms to demonstrate appropriate oversight and governance.
Board & Committee Governance Structures
- We assist firms in designing or refining board and committee structures that provide effective oversight of risk, compliance, strategy and operational performance.
- This includes governance charters, reporting structures and committee mandates aligned with regulatory expectations.
SMCR & Governance Frameworks for Accountable Financial Services Organisations
Effective governance is central to how regulated financial services firms operate, make decisions and demonstrate accountability to regulators, investors and stakeholders.
Cambitas advises FCA-regulated firms on the design, implementation and enhancement of SMCR and governance frameworks that support clear leadership accountability, effective oversight and credible regulatory compliance.
Our advisory services are designed for firms that require practical support in structuring governance arrangements aligned with the Senior Managers and Certification Regime (SMCR) and wider FCA expectations around culture, conduct and responsibility.
We work with boards, senior managers, compliance leaders and internal legal teams to build governance frameworks that function effectively in practice — not simply on paper.
If your organisation is implementing SMCR, strengthening governance arrangements or preparing for regulatory scrutiny, Cambitas provides structured advisory support tailored to the realities of regulated firms.
How We Work
Regulatory Analysis
Identify exposure and opportunities in your business model.
Governance Design
Align decision-making structures with supervisory expectations.
Licensing Preparation
Prepare documentation, operational evidence, and governance arrangements.
Compliance Implementation
Embed functional policies, procedures, and controls.
Supervisory Readiness
Strengthen credibility for regulators, investors, and banks.
Our Clients
Who We Work With
Cambitas supports regulated firms and leadership teams responsible for governance accountability.
Banks & Investment Firms
We assist banks and investment firms in designing governance frameworks that reflect complex operating models while meeting FCA expectations around accountability and oversight.
Payment & E-Money Institutions
Payment and e-money firms often experience rapid growth and evolving regulatory requirements. We help these firms structure governance arrangements that support sustainable regulatory compliance.
Asset Managers & Brokers
We advise asset managers and brokerage firms on governance design, SMCR responsibilities mapping and board oversight structures aligned with FCA expectations.
Fintech Firms Becoming Regulated
For fintech businesses entering regulated markets, governance frameworks must often be designed from the ground up.Cambitas supports firms transitioning from startup structures into regulated operating models.
Boards & Senior Leadership Teams
Non-executive directors and board members often require independent support in assessing governance effectiveness and ensuring accountability frameworks function properly.
Compliance & HR Functions
Compliance and HR teams play a central role in SMCR implementation, certification oversight and conduct rules compliance. We work closely with these teams to build workable frameworks and processes.
Regulatory Environment
UK Regulatory Environment
Senior Managers & Certification Regime (SMCR)
The Senior Managers and Certification Regime (SMCR) is the FCA’s framework for strengthening individual accountability within financial services firms. It was introduced to ensure that senior leaders are clearly responsible for the areas they oversee and that firms can demonstrate appropriate governance and oversight structures
Individual Accountability
Under SMCR, senior leaders must be able to demonstrate that they have taken reasonable steps to manage the areas of the business for which they are responsible.
This significantly increases the importance of clear governance structures and properly documented responsibilities.
Conduct Rules
SMCR also introduces Conduct Rules that apply to most employees within regulated firms. These rules establish basic standards of behaviour relating to integrity, due skill and care, and cooperation with regulators.
Challenges
Common Regulatory Challenges
Regulated firms frequently encounter governance issues during growth or regulatory change.
Unclear accountability structures
Senior managers may hold overlapping responsibilities or unclear mandates, creating governance risk.
Rapid growth without governance maturity
High-growth fintech and payment firms often outgrow informal leadership structures and require more robust governance models.
Ineffective governance documentation
Governance frameworks sometimes exist on paper but fail to reflect how decisions are actually made within the organisation.
Board oversight weaknesses
Boards may lack clear committee structures or defined reporting lines necessary for effective oversight.
SMCR remediation following FCA feedback
Firms occasionally receive supervisory feedback requiring improvements to governance frameworks or accountability mapping.
Difficulty evidencing decision-making accountability
Without clear governance frameworks, firms can struggle to demonstrate who was responsible for key decisions and how oversight was exercised.Addressing these issues early helps firms avoid regulatory escalation and strengthen internal leadership clarity.
Why Choose Us
Why Cambitas
- Specialised in financial regulation and digital markets.
- Aligns accountability with supervisory evaluation.
- Policies and controls designed to operate in live business environments.
- Direct work with founders, boards, and executives.
- Insight into token economies, decentralised governance, and digital infrastructure.
The Process
Engagement Process
Frequently asked questions
Frequently asked questions
Which firms must comply with SMCR?
SMCR applies to most FCA-regulated firms in the UK, including banks, investment firms, asset managers, payment institutions and many other financial services businesses.
The scope and complexity of SMCR obligations vary depending on the firm's regulatory classification.
What are Senior Manager responsibilities?
Senior Managers are responsible for clearly defined areas of the firm's operations.
They must understand their regulatory obligations, maintain a Statement of Responsibilities and demonstrate that they have taken reasonable steps to manage their areas effectively.
How often should governance frameworks be reviewed?
Governance frameworks should be reviewed periodically and whenever there are significant organisational changes, such as growth, restructuring, leadership changes or regulatory expansion.
Regular reviews help ensure accountability structures remain accurate and effective.
What triggers SMCR remediation?
Remediation may be required following FCA supervisory feedback, internal governance reviews, organisational restructuring or regulatory change.
Firms often reassess SMCR frameworks when responsibilities become unclear or governance documentation becomes outdated.
How does the FCA assess governance effectiveness?
The FCA evaluates governance effectiveness through supervisory engagement, document reviews and regulatory reporting.
The regulator will typically look at how responsibilities are allocated, how decisions are documented and whether governance structures operate effectively in practice.
What happens if governance arrangements fail expectations?
Where governance frameworks do not meet regulatory expectations, the FCA may require firms to undertake remediation work.
In more serious cases, governance weaknesses may lead to enforcement investigations or increased supervisory scrutiny.
Need Legal Support?
Strengthen Governance and Accountability with Confidence
Clear governance structures enable regulated firms to operate with confidence, demonstrate accountability and withstand regulatory scrutiny. Cambitas supports organisations implementing, enhancing or remediating SMCR and governance frameworks aligned with FCA expectations.
Cambitas
- +62 812 3456 7890
- 123 Corporate Avenue, Jakarta, Indonesia
- contact@lawfirm.com