How to Structure a SIMR Governance Map That Withstands PRA Challenge

A Governance Map is not a compliance artefact. It is the PRA's primary reference for who is accountable for what inside your firm, and supervisors will test it against board minutes, committee terms of reference, Statements of Responsibilities, and real decisions. If the Map and the reality diverge, the PRA notices, and the conversation shifts from governance quality to governance credibility.

Start With What the Map Is Actually For

Under SIMR (now integrated with the SM&CR for insurers), the Governance Map must show every Senior Insurance Management Function (SIMF) and Key Function Holder, their responsibilities, reporting lines, and how responsibilities are allocated across the firm. The PRA uses it to answer one question quickly: if something goes wrong here, who is accountable, and can they act?

Build the Map to answer that question without ambiguity. If a supervisor has to cross-reference three other documents to work out who owns conduct risk in the life book, the Map has failed.

Build the Core Structure Deliberately

A credible Map typically contains:

• A clear list of all SIMFs, Key Function Holders, and Notified NEDs, with named individuals, approval dates, and function codes.
• Prescribed Responsibilities and how they are allocated, with no gaps and no unexplained overlaps.
• Reporting lines, both solid and dotted, showing how each SIMF connects to the board and to one another.
• Committee structures with chairs, members, quorum, and the SIMFs accountable for each committee's output.
• Delegations, including what has been delegated, to whom, and the SIMF who retains accountability.
• Group context where relevant: matrix reporting, shared services, and how group-level decisions bind the UK entity.

The common failure point is the delegation layer. Firms describe what is delegated but not the accountability that remains. The PRA reads that as abdication.

Reconcile Against Everything Else

Before any version of the Map is signed off, reconcile it line by line against:

• Individual Statements of Responsibilities.
• Board and committee terms of reference.
• The Responsibilities Map required under Fitness and Propriety rules.
• Actual delegated authority schedules.
• Recent board minutes evidencing who made which decisions.

If a SoR says an individual is responsible for operational resilience but the Map shows that responsibility sitting with a committee chaired by someone else, you have a problem. Fix it in the underlying reality first, then reflect it in the Map.

Build Change Control That Actually Works

The PRA expects the Map to reflect current reality. That means a defined process: trigger events (new SIMF approval, role change, committee restructure, material outsourcing), owner (usually the Company Secretary or Chief of Staff), SIMF sign-off (typically the SMF1 or Chair), and a target update window of five to ten working days.

Maintain a version history with dated entries and the reason for each change. When supervisors ask how you know the Map is current, this is your answer.

Stress-Test Before the PRA Does

Take three recent events: a significant decision, an incident or near-miss, and a senior handover. Trace accountability through the Map. Can you show, using only the Map and supporting documents, who was accountable, who was consulted, and who executed? If the trail breaks, the Map needs work, or the governance does.

Good firms do this exercise quarterly. The best firms do it before every supervisory meeting.

What Good Looks Like

A Map that a new supervisor can read in thirty minutes and understand your firm's accountability architecture. No unexplained gaps, no overlaps that confuse ownership, no delegations that look like accountability transfers. Every SIMF can describe their responsibilities in terms consistent with the Map, and the Map is consistent with how the board actually runs.

The Next Decision

Before your next supervisory touchpoint, commission a reconciliation exercise between the Map, every current SoR, and the last six months of board and committee minutes. If that exercise cannot be completed in two weeks, your Map is further from reality than you think, and that is where to start.

Frequently Asked Questions

How often should the Governance Map be formally reviewed?

Formal board-level review should happen at least annually, but the Map itself should be updated within days of any triggering event. Treating annual review as sufficient is one of the more common supervisory criticisms.

Who should own the Governance Map?

Operational ownership typically sits with the Company Secretary or a dedicated governance function. Accountability sits with the Chair or CEO, depending on firm structure. The PRA will expect a named SIMF to own its accuracy.

What is the most common supervisory finding on Governance Maps?

Misalignment between the Map, Statements of Responsibilities, and how decisions are actually taken. Supervisors increasingly test this by tracing specific decisions through the documentation.

How should group reporting lines be shown?

Explicitly. Show matrix relationships, group committee memberships, and any reserved matters. Opacity on group structure is read as a governance weakness, particularly for UK subsidiaries of overseas parents.

Does the Map need to cover Key Function Holders below SIMF level?

Yes. The SIMR framework requires Key Function Holders to be identified and their responsibilities documented. Omitting them creates gaps the PRA will probe.