The accountability map that outlives the certificate
The PRA and FCA propose to scrap the Certification Regime and routine responsibility-map submissions. The certificate was only ever the receipt — the firms that keep the map alive as an operating artefact are the ones that will be ready.
What it is
On Thursday 22 October, the PRA and FCA published parallel consultations, CP14/26 and CP26/37, proposing the most significant reform of the Senior Managers and Certification Regime since it was introduced in 2016. If enacted, the package removes the Certification Regime entirely, covering around 139,000 certified individuals and some 7,700 PRA-certified staff. Pre-approval disappears for a range of senior manager functions, including chief actuaries and the chairs of risk and audit committees, replaced by notification to the regulator. The PRA expects its pre-approvals to fall by 43% and the overall burden of its regime to halve, saving firms a projected £2 billion over ten years. CEOs, CFOs and chairs keep their fit-and-proper approvals. Conduct standards remain. But the annual certificate, the fitness-and-propriety assessment on appointment, the regulatory references, and the routine submissions of Statements of Responsibilities and Responsibility Maps all go, with the maps dropped entirely for firms with a single senior manager. The consultations close on 22 January, and the whole package rides on the Financial Services and Markets Bill working its way through Parliament.
Why it matters now
Because for the first time, the question of who maintains the accountability map has a date attached to it. Since 2016, the answer was easy: the firm maintains the map because the regulator requires it, annually, with signatures and certificates attached. That is a very convenient reason to have a map. It is also a fragile one, because a map that exists because someone asks for it disappears the day they stop asking.
The HDI fine from the summer is the warning, read backwards. When the PRA fined HDI £4.165m over its FSCS levy reporting, the firm's failure was not missing paperwork. The firm had responsibility maps and approved senior managers. What it lacked was an accountability chain that reached the process step where the number was produced. The fine was the regulator demonstrating that accountability documented but not operational is not accountability. Now the regulator is proposing to stop asking for the documentation and keep the operational standard. The firms that relied on the annual ask are about to lose their only reason for maintaining the map. The firms that built the map to run the business never needed the certificate in the first place.
The second half of the announcement points the same way. The same Mansion House week saw the PRA unveil a five-year strategy built on data and technology, and the FCA set out plans to become an agentic regulator, automating supervision and enforcement with AI. A supervisor that stops checking annual certificates and starts reading the firm's data is not a lighter-touch regime. It is a different examination: no revision material, no scheduled sitting, graded continuously on what the data shows.
What firms should do
Treat notification as a capability, not an admin change.
When the chief actuary's appointment moves from pre-approval to notification, the regulator is telling the firm it trusts the firm's own judgement, and will test that trust afterwards. The firms that move fastest through notification are the ones that can evidence fit and proper on demand, which means the assessment has to be real and documented at the point of appointment. The process gets lighter; the internal standard has to get heavier.
Keep the responsibility map alive as an operating artefact.
The proposal removes routine SoR and MRM submissions, not the underlying requirement to know who is responsible for what. The map's future is as a management tool, versioned when processes change, used in handoffs and reviews, connected to the systems and process steps it describes. If the map is not used between submission cycles, it will not survive the moment the submission cycles stop.
Build the conduct evidence layer now.
With breach reporting thresholds raised and certification removed, the evidence of conduct discipline shifts to the firm's own records: how breaches are spotted, escalated, and remediated. A firm that relied on the certification cycle to surface conduct issues will stop surfacing them. The firms that will do well under the new regime are the ones whose operational records, RAID logs, review trails, escalation chains, already contain the evidence the regulator will later come looking for.
Spend the freed compliance hours on the operational chain.
The projected savings are real: fewer forms, fewer certificates, fewer submissions. The firms that reinvest those hours in tracing their actual accountability chains, process step to owner to control, will be more resilient, not just cheaper. The firms that bank the savings and change nothing will have simply traded the certificate for nothing.
The opmodal perspective
This is the Architecture Canvas's home turf. The canvas maps what touches what: every process step to its owner, every system to the processes that depend on it, every control to the risk it mitigates. A responsibility map says the CFO is responsible for regulatory reporting. The canvas shows what that sign-off actually depends on: where the data originates, which system holds it, who prepares it, what checks run before submission, who reviews before sign-off. One is a form. The other is the operating model.
When the regulator stops asking for the form, the canvas is what remains. That is the real meaning of Thursday's consultation for the London market. The certificate was never the accountability; it was the receipt. The receipt is being withdrawn. The firms that can show the workings behind the receipt, the chain from named owner to evidenced step, will discover that a lighter regime plus a real operating model is a better position than a heavy regime plus a decorative one. The firms that cannot will discover what a supervisor does with data when it stops reading certificates.
Accountability after the certificate is not a paperwork problem. It is an operating model problem, and it always was.
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Accountability that works on paper is not accountability: the PRA's HDI fine, decoded
