Evidencing ‘Reasonable Steps’ Under SM&CR

Introduction

The biggest risk for senior managers working within an FCA or PRA regulated environment is a breach of the Duty of Responsibility under s.66A[5] Financial Services and Markets Act 2000. However, the regulator cannot take action where the senior manager can demonstrate they have taken ‘reasonable steps’ to control their area of the business effectively.

Clarity on what constitutes ‘reasonable steps’ and how to evidence that the appropriate reasonable steps have been taken is proving to be a challenge for many firms.

This bitesize webinar will provide practical guidance in respect of evidencing reasonable steps so that senior managers are comfortable and confident in managing their responsibilities in light of recent changes to SM&CR. The session is geared towards senior managers (SMFs) of FCA authorised and regulated firms, as well as heads of compliance and compliance managers.

What You Will Learn

This short webinar will cover the following:

• Introducing the Duty of Responsibility
• Outlining reasonable steps
• What does the evidence look like?
• The impact of non-financial misconduct rules

This pre-recorded webinar will be available to view from Friday 27th November 2026

Alternatively, you can gain access to this webinar and 2,400+ others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.