How to Structure an SM&CR Statement of Responsibilities to Avoid Accountability Gaps

A Statement of Responsibilities is not a job description. It is the evidentiary spine of individual accountability, and supervisors read it forensically when something goes wrong. The most common failure is not omission but ambiguity: responsibilities that look allocated but dissolve under questioning about who actually decided what. A well-structured SoR removes that ambiguity before a supervisor forces the issue.

Key Executive Takeaways

• Every Prescribed Responsibility and business area must map to exactly one SMF, with no residual language that lets accountability drift to committees or unnamed deputies.
• The SoR must reconcile precisely with the firm's Management Responsibilities Map, committee terms of reference, and delegation letters, because supervisors will cross-check them.
• Shared or split responsibilities are permitted but rarely defensible unless the split is documented with specific decision rights, not just functional overlap.

Start with the map, not the individual

Most SoRs go wrong because they are drafted individual-by-individual. The result is subtle overlap: two SMFs both accountable for aspects of financial crime, or a PR handed to the CEO by default because no one else wanted it. Begin instead with the Management Responsibilities Map. List every PR, every FCA and PRA business activity, and every material regulated function. Then allocate. Only once the map is clean should you draft individual SoRs from it.

This sequence forces you to confront the awkward questions early: who owns conduct risk in a business the CRO does not directly control? Where does the CFO's accountability for financial resources end and the Treasurer's begin? If you cannot answer these on the map, you cannot answer them in an SoR.

Write for the supervisor reading it after a failure

Assume the SoR will be read by an enforcement lawyer reconstructing a decision chain two years after the fact. That changes the drafting standard. Vague verbs, oversee, support, contribute, are useless. Use verbs that denote decision rights: approves, sets, allocates, escalates, signs off. If the SMF cannot veto or direct the activity, they are not accountable for it. Say so explicitly.

Avoid the temptation to pad the SoR with everything the SMF touches. Breadth without decision authority creates exposure without control. A tight SoR of clearly owned responsibilities is more defensible than a sprawling one that implies accountability the individual cannot actually discharge.

Handle shared responsibilities with discipline

The rules permit sharing, but shared PRs are a supervisory red flag. If you must split a responsibility, for instance between a UK CEO and a group function head, document the split with specificity: who approves policy, who approves exceptions, who owns escalation to the board, who signs the regulatory return. A single sentence saying the responsibility is jointly held will not survive challenge.

The same discipline applies to matrix reporting. If an SMF is accountable for an activity performed by staff who report elsewhere, the SoR should record the reporting line, the information rights, and the escalation route. Without that, the SMF is accountable in name only, and supervisors know it.

Reconcile against the wider control framework

Before sign-off, run three reconciliations. First, does every PR in SYSC 24 appear against a named SMF? Second, does each SMF's SoR align with their committee memberships and chair roles? An SMF chairing a committee that decides matters outside their SoR is a gap. Third, do delegation letters and authority matrices match? A CFO SoR that reserves capital decisions while the treasury delegation letter grants them to a subordinate is the kind of inconsistency that turns a supervisory visit into a Section 166.

What good looks like

A strong SoR is short, specific, and internally consistent with the map and the wider governance record. It uses decision-verbs, names the deputies and their limits, and identifies the committees through which the SMF discharges responsibility. It is refreshed on any material change, not annually by default, and the change history is preserved.

The next action is straightforward: pull your current Responsibilities Map alongside every SoR and test whether each PR has one owner, one set of decision rights, and one reconciled evidence trail. If any of the three is missing, fix it before a supervisor finds it.

Frequently Asked Questions

How often should an SoR be updated?

On any material change to responsibilities, reporting lines, or business scope. Waiting for the annual attestation cycle is a common error and creates a gap between reality and the document that supervisors will exploit.

Can a PR sit with a non-executive?

Yes, and several must, but be cautious about loading NEDs with executive-flavoured PRs they cannot realistically discharge. The Chair's PRs are defined; beyond those, NED accountability should reflect oversight, not operational control.

What is the biggest drafting mistake?

Using oversight language where decision language is required. Oversight without authority is not accountability, and an SoR full of oversight verbs invites the question of who actually decides.

How do we handle a responsibility that genuinely spans two SMFs?

Split it by decision right, not by topic. Specify which SMF approves what, at what threshold, and how disagreement is escalated. If you cannot articulate the split cleanly, the responsibility belongs to one person, not two.

Do supervisors compare SoRs across peers?

Yes. Both regulators benchmark allocation patterns across firms, particularly for PRs that are commonly misallocated such as financial crime, outsourcing, and conduct. Outlier allocations attract questions.