PRA analysis and consultation - SM&CR implementation and progress, December 2020

PRA analysis and consultation – SM&CR implementation and progress, December 2020

PRA analysis and consultation – SM&CR implementation and progress, December 2020


  • On 16 December 2020, the Prudential Regulation Authority (PRA) published a report setting out the findings of a PRA evaluation that reviewed the implementation of the SM&CR in order to assess how it is delivering against its original objectives
  • The evaluation findings confirm that SM&CR has helped to ensure that senior individuals in PRA-regulated firms take greater responsibility for their actions as well as making it easier for both firms and the PRA to hold individuals to account
  • The PRA accepts that, as with any new regime, there were some upfront implementation costs for firms and regulators and is reassured that 95% of the firms surveyed said the SM&CR is having a positive effect on individual behaviours
  • The PRA remains keen to further embed the SM&CR and so this evaluation identifies nine follow-up actions and recommendations to help refine the regime


The PRA has outlined these nine follow-up actions within three themes:

  • Theme 1: Holding individuals to account through the SM&CR
  • Theme 2: Myth busting and clarifying expectations
  • Theme 3: Application of the SM&CR to different business models

The PRA is asking all firms and interested stakeholders for further feedback on these subjects.   This is the first PRA evaluation to examine a broad area of domestic policy.

The 34-page document is not a formal consultation and does not set out specific proposals for amending either the PRA Rulebook or Supervisory Statements.

Based on this feedback, and after having consulted the FCA and HM Treasury where needed, the PRA will consider if there is a case for proposing changes, which if taken forward would be subject to the usual consultation process.

In addition, the PRA will continue to give feedback to firms individually or at a sector level if it identifies areas in which firms can improve their implementation of the regime.

Timeline with relevant dates to be logged on regulatory calendar

  • Consultation closes on Friday 26 February 2021.

Next steps

Any respondents need to send their comments and enquiries to the PRA by e-mail:

Xcina Consulting also recently completed our own SM&CR benchmark survey of solo- and dual-regulated firms to assess how SM&CR is being operationalised across the industry.

We have been holding individual debriefing workshops with the survey participants and we will organise an open webinar in early 2021 to share the survey insights more broadly with those who are interested.   Please let us know if you are interested in joining that webinar.

If anyone has specific questions or needs any advice, contact our specialists.

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