Has SM&CR made a difference?

Has SM&CR made a difference?

SM&CR required changes to governance, compliance and HR processes. Have these changes made a difference?

Author: AxiomHQ – axiomhq.com


The Senior Managers & Certification Regime (SM&CR) for insurers took effect in December 2018.  As part of the Solvency II regime, insurers were already subject to the Senior Insurance Managers Regime (SIMR) introduced in 2016.  Despite that, there were some new requirements.  For example:


  • New certification
  • New duty of responsibility
  • Seeking approval of additional senior manager functions
  • Allocating new prescribed responsibilities


It required changes to governance, compliance and HR processes as well as preparation of additional documentation.


The extension of SM&CR to all firms helped to align regulatory processes.  For example, the adoption of an approval process for all senior managers and a consistent method of supervisory oversight for all regulated firms.


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