Welcome to SMF Unlocked, the podcast from SMF Capital.
Today we are answering a question that matters to boards, CEOs, HR directors, compliance teams and anyone recruiting senior leadership into an FCA-regulated business.
How long does an SMF appointment actually take?
It sounds like a straightforward question, but there are several stages involved. Finding the right candidate is only the beginning. The firm must also complete its due diligence, assess fitness and propriety, obtain the necessary regulatory references and submit an appropriate application to the FCA or, where relevant, the PRA.
The appointment timeline therefore needs to account for both recruitment and regulatory approval.
Under the FCA's rules, an individual generally cannot start performing an SMF until the required approval has been granted, subject to specific exceptions such as the applicable temporary cover arrangements. (FCA guidance on SMF applications)
Let's look at the process step by step.
Stage One: Defining the Role
Before approaching candidates, the firm needs to establish exactly what it is recruiting for.
Is the requirement for an SMF1 Chief Executive, an SMF2 Chief Finance function holder, an SMF4 Chief Risk Officer, an SMF16 Compliance Oversight function holder, or another senior management function?
The answer affects the candidate profile, the responsibilities involved and the evidence needed to support the application.
The firm should also establish how the role fits within its existing governance structure.
What responsibilities will the individual hold? Who will they report to? Will they manage a team? How much authority will they have? Does the firm's Statement of Responsibilities or, where applicable, its Responsibilities Map need to be updated?
Stage Two: Finding the Right Candidate
The recruitment phase can vary considerably.
If the firm already knows a suitable internal candidate, the process may be relatively quick.
If it needs to conduct an external search for a specialist executive, it may take considerably longer.
For an external appointment, a reasonable initial planning assumption might be four to eight weeks to identify, approach, assess and shortlist candidates. Difficult searches, particularly for specialist risk, compliance or international leadership roles, can take longer.
The timetable depends on several factors:
How specialised the function is
The seniority and experience required
The availability of suitable candidates
The firm's location and sector
Remuneration and other terms
The complexity of the interview and assessment process
Whether the appointment is permanent or interim
It is important not to confuse a quick shortlist with a completed recruitment process.
For an SMF role, the firm needs to understand the candidate's actual responsibilities and regulatory experience, not simply their previous job titles.
Stage Three: Interviews and Due Diligence
Once a preferred candidate has emerged, the firm needs to assess whether they are suitable for the proposed function.
This goes beyond a conventional executive interview.
The firm's assessment should consider honesty, integrity and reputation; competence and capability; and financial soundness.
Depending on the circumstances, due diligence may include criminal record checks, regulatory references, employment history checks, qualifications, conflicts of interest and an assessment of the candidate's relevant experience.
The firm must be satisfied that the candidate is fit and proper before submitting the application.
Regulatory references are particularly important. The FCA's framework generally requires relevant references covering the preceding six years, with serious misconduct potentially requiring disclosure outside the usual six-year period.
The FCA expects regulatory references to be provided as soon as reasonably practicable and indicates that six weeks is the maximum expected period in the usual case, rather than a target to wait for.
This is one reason to begin reference checks early.
A candidate may be ready to accept an offer, but a delayed reference or unresolved due diligence issue can hold up the application.
For planning purposes, allow around two to four weeks for straightforward due diligence, potentially running alongside later recruitment stages. Complex employment histories or difficult-to-obtain references can extend this period.
Stage Four: Preparing the FCA Application
The next stage is preparing the application for regulatory approval.
For an FCA application, this normally involves Form A and supporting information submitted through the relevant regulatory system. Dual-regulated firms may also need to follow the PRA-led process for functions within the PRA's remit.
The firm should be ready to explain why the candidate is suitable and how the proposed role will operate in practice.
The FCA identifies several common causes of delay, including:
Incomplete applications
Insufficient explanation of how responsibilities are allocated
Regulatory references or criminal record checks not completed before submission
An inadequate skills-gap analysis
An out-of-date Responsibilities Map where one is required
Incomplete disclosure of directorships
Insufficient information about conflicts of interest
Unclear evidence that the candidate has enough time to perform the role
Slow responses to follow-up questions
These are avoidable problems in many cases.
The FCA expects firms to submit a full and complete application from the outset. Preparing the supporting material properly can therefore make a meaningful difference to the overall timetable.
Stage Five: FCA Approval
How long does the regulator take?
The FCA must generally determine a properly completed SMF application within three months. If it requests further information, the assessment clock can be paused while the firm provides the information or completes an interview.
However, the statutory period should not be confused with the time every application actually takes.
The FCA publishes processing statistics and has reported that most FCA-led senior manager applications are determined significantly before the three-month deadline. Its published median processing time was 41 calendar days in the operating metrics cited in its 2025 reform consultation. That is historical performance data, not a guarantee of how long a new application will take.
The key points are:
Some applications are decided relatively quickly.
More complex cases can take longer.
The FCA may ask for further information or interview the candidate.
Incomplete applications can delay the process.
The firm, rather than the candidate, receives the FCA's progress updates.
You should therefore plan around the actual complexity of the appointment rather than assuming approval will arrive within a particular number of days.
You can read the regulator's guidance on how the FCA assesses SMF applications.
So, What Is a Realistic Overall Timeline?
For a new external SMF appointment, a useful planning estimate is around two to four months from the start of the recruitment process to regulatory approval, assuming a reasonably straightforward search and a well-prepared application.
This is a planning estimate, not an FCA service standard or a guarantee.
A simple internal appointment may be completed more quickly. A complex external search, difficult reference process, governance restructuring or regulatory follow-up may push the timetable beyond four months.
Here is an illustrative breakdown:
Stage
Indicative planning time
Define the role and responsibilities
1–2 weeks
Search and shortlist candidates
4–8 weeks
Interviews and due diligence
2–4 weeks, partly overlapping
Application preparation
1–2 weeks, partly overlapping
FCA assessment
Several weeks; statutory period generally up to 3 months for a complete application
These stages overlap, so the figures should not simply be added together. The overall timetable depends on the search, the quality of the application and the regulator's assessment.
The most important lesson is that the recruitment search and the regulatory approval process must be planned together.
Can the Candidate Start Before Approval?
For an ordinary new appointment, the answer is generally no.
An individual who requires approval to perform an SMF must not begin performing that function until the necessary approval has been granted.
There are, however, specific arrangements for certain unexpected or temporary vacancies.
The FCA's 2026 changes provide greater flexibility around the 12-week rule. Where the relevant conditions are met, a person may temporarily perform an SMF without prior approval, and firms now have up to 12 weeks to submit an application. The rule is intended to help firms manage unexpected absences or departures, not to replace proper succession planning or the normal approval process.
Firms should check the current rules and their own circumstances before relying on this arrangement.
You can read the FCA's guidance on preparing to apply for an SMF.
How Can Firms Avoid Unnecessary Delays?
There are several practical steps that can make an SMF appointment more efficient.
First, define the role properly. Be clear about the function, responsibilities, reporting lines and authority before starting the search.
Second, start due diligence early. Do not wait until the preferred candidate has accepted an offer before identifying potential reference or documentation issues.
Third, prepare the application carefully. Make sure the Statement of Responsibilities, skills-gap analysis and any required Responsibilities Map are consistent with the proposed appointment.
Fourth, check the candidate's capacity. The regulator may want to understand other directorships, existing roles and whether the candidate has sufficient time to perform the function.
Fifth, respond promptly to questions. Delayed responses to the regulator can prolong the process.
Finally, build a realistic start date into the recruitment plan. Avoid making commercial commitments that depend on an approval date the firm cannot control.
Why Specialist SMF Recruitment Helps
An SMF appointment is not simply an executive search followed by an administrative application.
The recruitment process needs to take account of the responsibilities, experience and regulatory expectations attached to the function.
This is where specialist recruitment can help.
SMF Capital works with regulated businesses looking to appoint senior managers across relevant functions. Understanding the role from the outset helps firms focus on candidates whose experience is aligned with the responsibilities they will be expected to carry.
It can also help identify potential issues early, including gaps in relevant experience, competing commitments or questions that may need to be addressed in the application.
No recruiter can guarantee regulatory approval or control the FCA's decision. The value lies in a better-informed search and a more organised appointment process.
Final Thoughts
How long does an SMF appointment actually take?
For planning purposes, allow around two to four months for a straightforward external appointment, while recognising that the process may be shorter or longer depending on the search, due diligence and regulatory assessment.
The FCA's statutory decision period is generally three months from receipt of a properly completed application, but that is only one part of the overall timetable.
The firms that plan effectively are those that treat recruitment, due diligence, governance documentation and regulatory approval as connected stages of one process.
If your business is preparing to appoint an SMF, the best time to consider the approval timetable is before the recruitment search begins.
For more information, visit SMF Capital and explore its guidance on SMF appointments and specialist recruitment for regulated businesses.
Thank you for listening to SMF Unlocked.