SMF18 Best Practice Areas: Overall Responsibility

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 slice, SMF18 is the function that catches everything else.

The risk with SMF18 is rarely the role. 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 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, even for an area you do not run day to day.

From July 2026 an SMF18 holder at a solo regulated firm can hold any prescribed responsibility, not just the old CASS exception, so this is a timely moment to revisit how your responsibilities are allocated.

This bitesize webinar supports current SMF18 holders and those preparing to take the function. It focuses on practical approaches and the judgment the role needs, rather than detailed regulatory requirements.

What You Will Learn

This short webinar will cover the following:

• Explain the scope of the SMF18 function and how overall responsibility differs from the CEO function and the named functions
• Test whether your Statement of Responsibilities and the firm’s responsibilities map leave any gaps or overlaps
• Understand the new freedom to allocate any prescribed responsibility to an SMF18 and how to use it without creating fresh accountability gaps
• Apply oversight and delegation practices that hold accountability for areas you do not run day to day
• Take practical steps to evidence reasonable steps and know when to escalate

This pre-recorded webinar will be available to view from Monday 4th January 2027

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.