How to Allocate Prescribed Responsibilities in an SMCR Statement of Responsibilities

The single most common failing in an SoR is not length or formatting. It is the quiet mismatch between what the document says a Senior Manager is responsible for and what the firm's governance actually does. Prescribed Responsibilities (PRs) are where that mismatch becomes visible first, because each one must sit with a named individual who can credibly demonstrate oversight. Get the allocation wrong and you create either duplication (two people accountable, neither decisive) or a gap (no one answerable when something fails).

Start with the PR list, not the people

The instinct is to look at the current Senior Manager population and distribute PRs across them. Reverse this. Begin with the full PR list applicable to your firm (Core, Enhanced, or Limited Scope under FCA rules, plus PRA PRs for dual-regulated firms) and ask, for each: who in this firm actually has the authority to ensure this is delivered? If the honest answer is "no one at SMF level," you have a structural issue to fix before the SoR is drafted.

Pay particular attention to the PRs that are habitually mis-allocated: responsibility for the firm's policies and procedures for countering financial crime (often parked with the MLRO when it should sit with an SMF), responsibility for the firm's performance of its obligations under the Certification Regime, and responsibility for induction, training and professional development.

Allocate to the role, test against the person

A PR belongs with the SMF whose remit genuinely covers it. Then test whether the individual holding that SMF has the seniority, information flows, and committee access to discharge it. If they do not, either change the allocation or fix the access. Do not allocate a PR to someone whose only connection to the subject is that no one else wanted it.

For dual-hatted individuals (common in smaller firms), be explicit about which capacity the PR sits in. A CEO who also chairs the risk committee should not have risk-related PRs allocated ambiguously between the two roles.

Write the responsibility in operational language

The SoR text for each PR should describe what the Senior Manager actually does to discharge it: what they approve, what they receive, which committees they chair or attend, what escalation they own. "Responsible for X" is not enough. "Chairs the Financial Crime Steering Committee, approves the annual MLRO report before board submission, and receives monthly KRI packs covering sanctions, AML and fraud" is the standard to aim for.

This also disciplines the allocation: if you cannot describe the operational reality, the allocation is probably wrong.

Eliminate overlap deliberately

Where two SMFs genuinely share oversight of an area (for example, a CRO and a CFO on capital adequacy), the PR must still sit with one. Document the interface in the Responsibilities Map and in both SoRs, but do not split the PR itself. Split allocations are the single clearest signal to a supervisor that accountability has not been thought through.

Reconcile against the Responsibilities Map

The SoR and the Management Responsibilities Map must tell the same story. Before finalising, run a line-by-line reconciliation: every PR in the SoR appears in the Map, every Map entry is reflected in the relevant SoR, and the committee structures referenced exist and meet as described. Discrepancies here are what supervisors find first.

What good looks like

A well-structured SoR reads as if the Senior Manager wrote it themselves and could defend every line in an interview. It names specific committees, specific approval authorities, specific information flows. It does not hedge. It does not duplicate. It matches the Map, the committee terms of reference, and the actual MI the individual receives.

Next step

Pull your current SoRs and PR allocations together with the Responsibilities Map. Run the reconciliation this week. Any PR you cannot trace to a named SMF with operational authority and evidenced information flows is a gap that needs fixing before your next supervisory touchpoint, not after.

Frequently Asked Questions

Can a Prescribed Responsibility be shared between two Senior Managers?

Only in narrowly defined circumstances permitted by the rules (such as job-share arrangements). In practice, sharing a PR almost always creates ambiguity. Allocate to one individual and document interfaces separately.

What happens if a PR is not allocated at all?

The firm is in breach. More importantly, the absence signals that no one is accountable for the underlying activity, which is a governance failure before it is a regulatory one. Every applicable PR must be allocated.

How often should SoRs be refreshed?

Whenever there is a significant change in responsibilities, a new SMF appointment, a material change to the firm's structure, or a Responsibilities Map update. An annual review is a minimum, not a ceiling.

Should the SoR reference the Certification Regime?

Yes, where the relevant PR applies. The Senior Manager holding responsibility for the firm's performance of its Certification obligations should describe how they oversee the annual fitness and propriety assessments, not merely assert that they are responsible.

Who should sign off the SoR internally before submission?

The individual Senior Manager, the Chair or CEO as appropriate, and the body with governance oversight of SMCR (usually the Nomination Committee or Board). Record the sign-off trail.