Senior manager pre-approvals face 43 percent reduction
BOE Paper

Senior manager pre-approvals face 43 percent reduction

Senior manager appointments would require fewer approvals under the Prudential Regulation Authority (PRA) consultation published on October 22, 2026. It proposes ending certification requirements for approximately 7,700 people and cutting pre-approvals by 43 percent.

Notification replaces advance scrutiny

The PRA proposes replacing pre-approval with notification for almost half of Senior Manager Functions, including chief actuaries and risk and audit committee chairs.

Firms would retain fitness and propriety checks and senior accountability standards; the PRA could require approval in exceptional cases.

Certification assessments on appointment and annually, certificates and regulatory references would end for formerly certified staff.

Competence, integrity and conduct obligations would remain.

Temporary cover would increase from 12 to 18 weeks.

Implementation is envisaged for H2 2027, subject to the Financial Services and Markets Bill 2026.

Responses close January 22, 2027.

Savings carry a transition cost

Around 1,200 firms fall within scope.

The PRA estimates annual costs would fall from £24.8 million to £13.3 million, saving £11.5 million, or 47 percent; savings range from £4.8 million to £24.9 million.

One-off familiarisation costs total £4.3 million.

Certification removal accounts for £6.0 million of annual savings.

Alongside the Financial Conduct Authority (FCA) and HM Treasury, the PRA targets a 50 percent burden reduction and 40 percent fewer pre-approvals across reforms.

The FCA is consulting in parallel.

Less scrutiny, retained responsibility

The PRA acknowledges that notification removes scrutiny before appointments and risks identifying suitability concerns later.

It relies on firms' vetting, senior accountability and exceptional pre-approval powers to mitigate this.

Its savings estimates rely on self-reported data with an uneven sector sample.

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