What this means
Start with the exact decision in front of you.
An FCA case against a Senior Manager may examine whether a regulatory contravention occurred in the area for which the manager was responsible and whether reasonable steps were taken. Responsibility maps, governance and escalation evidence therefore matter.
Immediate priorities
Organise the position before responding.
Secure statements of responsibilities and management maps
Build a dated record of decisions, challenge and escalation
Separate personal responsibility from the firm's systems findings
Detailed guidance
The procedure, evidence and possible route from here.
01
Define the responsibility before judging the steps
A duty-of-responsibility case begins with an alleged contravention by the firm in an area for which the Senior Manager was responsible. Secure the statement of responsibilities, management responsibilities map, committee terms, delegation documents and role changes covering the relevant period. Formal documents matter, but investigators may also examine how authority worked in practice. Avoid expanding ownership merely because the person was senior or attended a committee where the issue appeared.
The FCA then considers whether the Senior Manager took reasonable steps to prevent or stop the contravention. That is context-sensitive. Size, complexity, information available, competing priorities, delegation, escalation and the duration of the problem may all matter. Build a dated account of what the manager knew, what questions were asked, what assurance was received and how weaknesses were escalated. Later knowledge should not be projected backwards into an earlier decision.
- Collect every version of the responsibility documents
- Map formal authority against actual practice
- Fix knowledge and decisions to reliable dates
02
Evidence reasonable management action
Reasonable steps are shown through records of challenge, governance, resourcing, delegation, monitoring and follow-up. Board minutes alone may be too compressed, while personal notes without corroboration may be incomplete. Link each important decision to the information available at that time and the action assigned. Where the manager relied on specialists, explain why that reliance was reasonable, what reporting was required and what happened when assurances were not met.
A failure in the business does not automatically establish personal failure. Equally, delegation does not end accountability if warning signs were ignored or oversight was ineffective. Separate the root cause of the firm's contravention from the alleged omission by the Senior Manager. Evidence of prompt escalation, revised controls or resource requests may answer a different question from remediation completed after the issue became public, and the response should make that timing clear.
- Create a decision-and-escalation chronology
- Link delegation to monitoring and follow-up
- Separate prevention steps from later remediation
03
Coordinate firm and individual positions
The firm may admit control failures, settle its case or characterise governance in a way that affects the individual. Obtain the material on which those positions depend and identify any conflict in representation. An agreed firm narrative is evidence, not an automatic finding against a Senior Manager. Conversely, blaming systems in the abstract will not answer documents showing personal knowledge or authority. The individual's account should remain candid and source-based.
Possible consequences can include disciplinary action, financial penalty, withdrawal or variation of approval and prohibition. Those outcomes involve overlapping but distinct statutory questions. Prepare first for findings on responsibility and reasonable steps, then address fitness, deterrence and proportionality if required. Employment departure or loss of the particular role may change practical risk, but it does not necessarily resolve whether future controlled functions should be restricted.
- Identify conflicts between firm and personal positions
- Test firm admissions against the source record
- Address findings separately from future approval action
Key questions
Keep the analysis tied to this stage.
The relevant area of responsibility
What reasonable steps were available and taken
Whether an individual disciplinary case is supported
Advice is provided only by the regulated firm that accepts a matter.
Common questions
Clarifying the route without assuming the outcome.
Is a Senior Manager personally liable whenever their business area breaches a rule?
No. The FCA must apply the statutory duty-of-responsibility framework, including responsibility for the area and whether reasonable steps were taken in the circumstances.
Can I rely on delegation to another executive?
Delegation may be relevant, but the reasonableness of selection, clarity, oversight, information and follow-up will usually matter as well.
Connected guidance
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Official sources
Check the material for this question.
Sources checked 19 September 2026. Rules change, so compare the current notice and linked official material and tell the operator if a citation or summary needs correction.