Navigating SMF18 Responsibilities: Overall Responsibility in Practice

Introduction

The Other Overall Responsibility function (SMF18) is the part of SMCR that makes sure nothing falls through the cracks. It applies to the senior manager who holds overall responsibility for an area of the business that no other senior management function already covers. Where the CEO owns the whole firm and the named functions own their area, SMF18 is the function that catches everything else.

The risk with SMF18 is rarely the role itself. It is ambiguity. Gaps where no one quite owns a risk. Overlaps where two people each assume the other has it. Statements of Responsibilities that read well but do not match how the business actually runs. The Duty of Responsibility means that if something goes wrong in your area, you need to show the reasonable steps you took. That is harder to do for an area you may not run day to day.

The ground has just shifted. From July 2026 an SMF18 holder at a solo regulated firm can hold any prescribed responsibility, not just the old CASS exception. That is a welcome chance to align responsibility with the person who actually owns the area, rather than running an artificial workaround through another function. It also raises the bar on evidencing reasonable steps. This session is for current SMF18 holders, those about to be appointed, and the people who design the firm’s responsibilities map. You will gain clarity on what overall responsibility means in practice, how to draw clean boundaries, how to use the new prescribed responsibility freedom well, and how to evidence all of it before anyone asks.

What You Will Learn

This live and interactive course will cover the following:

• The SMF18 Mandate
• What overall responsibility means in practice
• How SMF18 differs from the CEO function and the named functions
• Why this is the function that closes the gaps
• Mapping Responsibilities Without Gaps or Overlaps
• Drawing clean boundaries across the firm
• Best practice for your Statement of Responsibilities
• The new freedom to allocate any prescribed responsibility to an SMF18 and what to do with it
• Aligning the responsibilities map with reality now the workaround has gone
• Keeping the map honest as the business changes
• Reasonable Steps When You Are Accountable but Not Hands On
• What reasonable steps looks like for an area you oversee rather than run
• Delegating the task without delegating the accountability
• Why more freedom over prescribed responsibilities raises, not lowers, the bar
• Building a defensible evidence trail before you need it
• Working With Other Senior Managers
• Handovers, shared areas and joint responsibilities
• Spotting and closing orphaned risks
• Your duty to escalate and when to use it
• Regulatory Engagement and Enforcement
• What the FCA looks for when it tests ownership and allocation
• Lessons from enforcement where accountability gaps caused harm
• Appointment, handover and planning your exit

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.