The £2 billion saving is the firms'. The public register was everyone else's
Dropping annual certification paperwork for 139,000 financial staff is defensible. Deleting their names from the public register — and raising the misconduct reporting threshold in the same package — is a separate decision.
Banks and insurers in Britain must name senior people who can be held personally responsible when things go wrong. A second layer, called certification, covered about 139,000 more junior staff: their employer had to check them every year, and their names appeared on a public register anyone could search. The two regulators now propose scrapping that second layer, saying it will save firms money and speed up hiring.
Dropping the annual paperwork for 139,000 staff is defensible. Deleting their names from the public register, while also raising the threshold for reporting misconduct, is not — it removes the evidence that would later show whether this worked.
Scrapping a form is one thing. Deleting a list is another
Britain’s two financial regulators have proposed taking about 139,000 people off the public register of who works in financial services. That is not how the announcement is framed — it is framed as removing annual certification checks and the administrative requirements around them — but it is what the proposal says. Certification and the Register entry travel together. End one and you end the other.
The Senior Managers and Certification Regime, now ten years old, was built in two layers. The top layer names individuals who are personally answerable for defined parts of a firm, and that layer is not being weakened here. The second layer covered staff below senior manager level whose work could cause significant harm: the firm had to assess them as fit and proper every year, and they appeared on the Financial Services Register, which anyone can search. The Prudential Regulation Authority and the Financial Conduct Authority now propose removing that second layer, alongside removing regulator pre-approval for roles including chief actuaries and chairs of risk and audit committees, and raising the threshold for reporting conduct rule breaches by most junior staff.
The easy part is genuinely easy
The pre-approval change deserves less argument than it will get. A firm appointing an audit committee chair already carries the consequences of appointing the wrong one, and waiting in a regulatory queue to confirm a choice the firm has already made, and remains liable for, is a cost with a thin benefit. Moving to notification, with the firm still responsible for establishing that the candidate is fit and proper, trades a procedural gate for speed in hiring. That is a defensible call, and the burden of proof sits with people who think the queue was doing work the firm’s own board was not.
The annual certificate is similar. It was never a regulator’s assessment. It was the firm assessing its own staff and keeping the paperwork. Doing that once a year rather than continuously, and writing it down in a prescribed form, is not obviously the thing standing between a customer and harm.
What does not follow from that
None of which gets you to deleting the directory. The Register entry is the only part of the certification layer that faces outward. It is how a customer, a journalist, a rival firm or a liquidator establishes that a named person held a named role at a named firm on a named date. Its value is not in the annual check behind it; its value is that it exists and is public, and that it persists after the person has moved on.
The regulators say high standards of individual accountability and conduct remain unchanged, including a commitment to holding individuals accountable for misconduct that affects society as well as their employers. Accountability of that kind runs on records. If you want to establish after the event that a particular person was responsible for a particular book of business, a public register that already says so is worth more than a firm’s archived internal file — particularly if the firm has since been acquired, or has failed, which is exactly when the question gets asked.
Three changes, one direction
The harder objection is not to any single element but to their combination. Removing the annual check reduces the firm’s internal evidence. Removing the Register entry removes the external evidence. Raising the conduct breach reporting threshold reduces the regulator’s inbound evidence. All three move the same way, and they move together.
That matters because of what happens next. In five years someone will ask whether removing certification made conduct worse. The honest answer will be that nobody can tell, because the series that would have shown it was discontinued at the same moment as the control. A regulator confident in a reform should want the measurement to survive it. Keeping the instrument costs almost nothing and is the cheapest insurance available against having to argue from assertion later.
The case against this argument
The strongest version of the other side is that the Register entry was never doing the work I am attributing to it. Most of the 139,000 are not people a retail customer ever meets or searches for. Searching the Register is a minority sport. And the certification layer, whatever its theoretical merits, absorbed real compliance resource that could have gone into supervising the handful of staff who actually create risk — which is precisely the argument for focusing effort where it counts.
Most of that is right, and it is an argument for a narrower register, not for no register. If the entries that matter are the customer-facing ones, keep those and drop the rest. The line should be drawn by whether a member of the public could plausibly need to look the person up, not by whether the person sits above or below a seniority threshold set for a different purpose. Drawing it the second way is easier to draft. It is not easier to defend.
This is a consultation, not a rule. The detail of which roles leave the Register, and whether any public record replaces the entries, sits in documents longer than the announcement. That is where the question should be settled — and it is a question that should be answered explicitly rather than absorbed into a savings estimate.
The Financial Conduct Authority should state plainly in its consultation whether customer-facing roles will keep a public Financial Services Register entry after certification ends, and if the answer is no, publish the reasoning rather than leaving it as a by-product of removing the certificate. It should also commit, now, to publishing conduct-breach statistics on a basis consistent enough to compare the years before and after the change.
And whoever responds to this consultation on behalf of consumers — the Financial Services Consumer Panel, the complaints service, the advice sector's own trade bodies — should ask for one number the regulators have not offered: how many of the 139,000 hold roles that deal directly with the public. Without it, the cost side of this trade is simply unmeasured.
What would change this view
I am wrong if the Financial Conduct Authority's consultation paper, or the policy statement that follows it, keeps public Register entries for customer-facing roles — retail investment advisers, mortgage advisers, insurance sellers — while dropping the annual certificate for everyone else. That is a line in a published document, and it is checkable within weeks.
I am also wrong if the FCA commits to publishing conduct-breach data on a consistent basis through the change, so a before-and-after comparison is possible. If either appears, the objection here collapses to a quibble about sequencing and the rest of the package stands on its merits.
Worked from
- Regulators unveil plans to simplify Senior Manager and Certification Regime
Bank of England · 2026-10-22