From Chartered Accountant to Senior Manager: Regulated Leadership Roles in London
Chartered accountants have always been well represented at the top of UK financial services. Finance directors, heads of internal audit, chief risk officers and even chief executives at banks, insurers and investment firms very often started their careers in audit or practice.
What has changed is what those senior roles involve. Since the Senior Managers and Certification Regime (SMCR) was introduced, the most senior people at regulated firms hold Senior Manager Functions. They need the regulator’s approval before they can start, and once approved, they are personally accountable for their areas of the business.
For accountants with ambitions in financial services, and particularly in London, where most of these roles are, understanding the Senior Managers regime is now part of career planning. This article sets out which Senior Manager roles suit finance professionals, what the regulator looks for, and how accountants can build the track record that leads to approval.
Why Accountants Are Well Placed
The regulator assesses every Senior Manager against the fit and proper standards: honesty and integrity, competence and capability, and financial soundness. A professional qualification doesn’t guarantee approval, but chartered accountants start with several advantages.
- A professional ethics framework. ICAEW, ICAS, ACCA and CIMA members are already bound by codes of ethics and subject to professional discipline, which sits naturally alongside the regulator’s Conduct Rules.
- Controls and governance experience. Audit training builds a habit of testing controls, challenging management and documenting judgements. That’s exactly the mindset the regime’s “reasonable steps” test rewards.
- Board-level reporting. Senior Managers report to boards and committees. Accountants who have presented to audit committees or prepared board packs already know how that works.
- Technical depth. Capital, liquidity, financial reporting and, for insurers, Solvency UK all draw on finance skills.
The ICAEW and the other professional bodies publish material on financial services careers and governance, and the FCA’s SMCR pages explain how the regime works across the market.
The Senior Manager Functions That Suit Finance Professionals
Several Senior Manager Functions are natural destinations for chartered accountants. Which ones apply depends on the type of firm: some functions are only required at dual-regulated firms such as banks and insurers, while others apply across the market.
| Function | Role | Typical route for an accountant |
|---|---|---|
| SMF2 Chief Finance function | Overall responsibility for the firm’s financial resources and reporting, mainly at dual-regulated firms | Financial controller or deputy CFO at a regulated firm, often after Big Four financial services audit |
| SMF3 Executive Director | Board director at a firm where no more specific function applies; often the CFO at a solo-regulated firm | Finance director at an asset manager, wealth firm or broker |
| SMF4 Chief Risk function | Overall responsibility for risk management | Risk, internal audit or regulatory reporting, moving into enterprise risk |
| SMF5 Head of Internal Audit | Leads internal audit at larger and dual-regulated firms | External audit, then internal audit leadership |
| SMF16 Compliance Oversight | Responsible for the firm’s compliance function | Regulatory reporting, audit or advisory work moving into compliance |
| SMF17 Money Laundering Reporting Officer | Responsible for anti-money laundering and financial crime controls | Forensic accounting, financial crime advisory or compliance |
SMF Capital’s complete guide to SMF designations covers every function, and its guide to SMF2, the Chief Finance function looks at the role most accountants aim for.
Why London Matters
Senior Manager roles exist across the UK, with significant markets in Edinburgh, Birmingham, Bristol and elsewhere. But London has the largest concentration of FCA and PRA-regulated firms and the widest range of Senior Manager roles.
It’s also several markets in one city. The City and Canary Wharf house banks, insurers and asset managers, many of them dual-regulated, which means more Senior Manager Functions and more demand for SMF2, SMF4 and SMF5. Mayfair and St James’s are home to hedge funds, private equity and wealth managers, where a finance director might hold SMF3 and sometimes combine finance with operations. Shoreditch, Old Street and King’s Cross host payments, e-money and crypto-asset firms, which need finance and compliance leaders who can work at start-up pace. And most overseas banks and insurers set up their UK operations in London, creating roles for accountants who can bridge UK requirements and an overseas parent.
The other side of the coin is competition. London has the deepest pool of approved Senior Managers in the UK, so firms can be selective, and candidates with a previous approval have a real advantage.
Building the Track Record the Regulator Looks For
For most accountants, the barrier to a first Senior Manager role isn’t ability but evidence. The regulator wants to see that a candidate’s experience matches the specific responsibilities they will hold. A strong financial controller who has always supported the CFO can find that harder to demonstrate than they expect.
Practical ways to build that evidence include:
- Deputise formally. Act as deputy to an existing Senior Manager, with that arrangement documented, and cover their role during absences.
- Attend the board and its committees. Present to the audit and risk committees, not just prepare the papers.
- Work with the regulator directly. Contribute to regulatory returns, attend supervisory meetings, and respond to regulatory requests.
- Own something. Take full responsibility for a discrete area, such as capital planning, a regulatory change project or a remediation, rather than supporting it.
- Keep your record clean. Regulatory references cover the previous six years, and directorships and financial soundness all form part of the assessment.
SMF Capital’s guide to the fit and proper test explains in detail what the regulator assesses.
What the Move Involves
A Senior Manager appointment in London takes longer than most senior moves. Search and shortlisting may take a few weeks, but experienced candidates typically have notice periods of three to six months, and the regulator then has a statutory period in which to decide on the application. Firms that plan well prepare the application and gather regulatory references while the candidate works their notice, which shortens the overall timetable considerably.
Pay at Senior Manager level in London is the highest in the UK, and packages at larger firms often include variable pay subject to deferral and clawback. Moving firms can mean forfeiting deferred awards, so buy-outs are a normal part of the conversation.
Before accepting a Senior Manager role, accountants should apply the same scepticism they would bring to an audit. Ask about open regulatory issues, the quality of the systems and data you’ll rely on, the resources you’ll have and why your predecessor left. You’ll be accountable for what you inherit.
Common Pitfalls for Accountants Seeking a First SMF Role
Accountants who make the move successfully tend to avoid a handful of common mistakes.
- Underselling accountability. CVs written for finance roles often describe tasks rather than responsibility. For a Senior Manager role, show what you owned, what you decided and how you escalated problems.
- Ignoring the firm type. SMF2 and SMF5 mainly apply at dual-regulated firms. Applying for “CFO” roles at solo-regulated firms and expecting an SMF2 approval can cause confusion. Check which function the role actually carries.
- Leaving disclosures late. Anything that might come up in a regulatory reference, a credit check or a directorship search should be raised early with the recruiter and the firm. Surprises at the application stage are what derail approvals.
- Treating approval as a formality. The regulator can and does question candidates, and for significant roles may interview them. Preparation matters.
Fractional and Interim Routes
Not every route into regulated leadership is a full-time permanent role. Smaller regulated firms increasingly appoint fractional Senior Managers, such as compliance officers, MLROs and finance directors working two or three days a week. For experienced accountants, that can be an effective way to gain Senior Manager experience across more than one firm, or to build a portfolio career. The regulator will expect the time commitment to be realistic for the firm’s size and risks, but fractional arrangements are now an accepted part of the market.
Where to Find Out More
SMF Capital, a sister practice within The Capital Recruitment Group, recruits Senior Managers for FCA and PRA-regulated firms, with every search led by a Chartered Accountant. Its SMF recruitment London page explains the London market in more detail, including the sectors, the Senior Manager Functions most in demand and what London hiring looks like in practice. Its Knowledge Centre has free guides to every function, the Conduct Rules and the approval process.
For chartered accountants with ambitions in financial services, the Senior Managers regime has made the path to the top more demanding, but also clearer. Build the evidence early, understand what the regulator will look for, and the step from senior finance professional to Senior Manager becomes a realistic one.
About the author: Adrian Lawrence FCA is a Chartered Accountant and Fellow of the ICAEW with a practising certificate, and a former listed-company Finance Director. He is the founder of FD Capital and SMF Capital, part of The Capital Recruitment Group, and leads every senior search personally.
