Day One: Understand What’s Leaving

Before anything else, establish exactly what the departing Senior Manager is responsible for. Pull out their Statement of Responsibilities and the firm’s Responsibilities Map, and list:

• the Senior Manager Functions they hold
• any Prescribed Responsibilities allocated to them
• other responsibilities recorded in their Statement of Responsibilities
• committees they chair or sit on, and regulatory relationships they manage
• any live regulatory matters, remediation programmes or open issues in their area.

At smaller firms, one person often holds several responsibilities, such as compliance oversight and money laundering reporting together. Losing that person can leave several gaps at once. Knowing the full picture on day one makes every later decision easier.

Week One: Agree the Notice Period and Handover

Confirm the Leaving Date

Senior Manager notice periods are often three to six months. Agree the leaving date and whether the individual will work their full notice. If they’re going to a competitor or leaving on difficult terms, garden leave may be appropriate, but remember that someone on garden leave may still be performing the function in the regulator’s eyes until the firm tells the FCA otherwise.

Plan the Handover

The regime expects firms to take reasonable steps to make sure an incoming Senior Manager has the information they need to do the job. Start the handover document now, while the departing holder is engaged. It should cover open issues, key risks, relationships with the regulator, ongoing projects and anything the successor will need to know in their first weeks. A good handover protects the successor, the firm and the departing individual, whose Duty of Responsibility covers the period they held the function.

Consider Regulatory References

If the departing Senior Manager is joining another regulated firm, you’ll receive a request for a regulatory reference covering their time with you. Make sure whoever will complete it understands the mandatory template and the disclosure requirements, and that the firm’s records are in order.

Weeks One and Two: Reallocate Responsibilities

Decide Who Covers What

No Prescribed Responsibility can be left unallocated, and the firm must be able to show who is responsible for each part of the business at all times. Decide who will take on each of the departing holder’s responsibilities from their leaving date. Options usually include:

• reallocating responsibilities temporarily to an existing Senior Manager who has the capacity and knowledge
• asking a deputy or head of function to cover the role under the 12-week rule
• bringing in an interim or fractional Senior Manager.

Use the 12-Week Rule Properly

Where a Senior Manager leaves unexpectedly or for a temporary reason, the 12-week rule allows someone to perform the function without prior approval for up to 12 weeks in a consecutive 12-month period. Since the April 2026 reforms, the firm must submit an approval application within those 12 weeks if the person covering is to continue in the role, rather than needing approval to be granted within 12 weeks. The Senior Manager Conduct Rules apply to the person covering. Note that the rule is designed for unforeseen or temporary absences, and a resignation with a long notice period is usually foreseeable, so firms should plan approvals for the permanent successor rather than rely on the rule.

Update the Responsibilities Map

Once the reallocation is agreed, update the Responsibilities Map and the relevant Statements of Responsibilities. Where an existing Senior Manager takes on significant new responsibilities, the firm will usually need to submit a revised Statement of Responsibilities to the FCA.

By the Leaving Date: Make the Notifications

When a Senior Manager stops performing a function, the firm must notify the regulator using Form C within seven business days, as set out in SUP 10C of the FCA Handbook. Dual-regulated firms also notify the PRA. Where the departure involves concerns about the individual’s conduct or fitness, the notification must say so, and the firm may need to consider other obligations too.

It’s good practice to speak to the firm’s supervisor before the departure, particularly where the individual holds a significant role such as Chief Executive, Chief Risk Officer or compliance oversight or MLRO. Supervisors prefer to hear about senior changes from the firm rather than discover them from a form.

Weeks Two to Four: Start the Search

Rethink the Role Before Advertising It

A departure is an opportunity to ask whether the role is still right. Has the firm grown to the point where combined functions should be separated? Does the firm now need an experienced holder rather than a first-time appointment, or the reverse? Is the role better suited to a fractional arrangement? A governance and SMF structure review can help answer these questions quickly.

Plan Around the Approval Timetable

The regulator can take up to three months to decide a complete application, and the successor will probably have a notice period of their own. Starting the search immediately gives the best chance of avoiding a long gap. Our guide to how long an SMF appointment actually takes sets out a realistic timeline.

Build Fitness and Propriety Into the Search

The quickest way to lose time is to choose a candidate who then struggles at approval. Test shortlisted candidates against the fit and proper test before an offer, and request references early. Our SMF recruitment service builds this into every search, and our interim and fractional cover can bridge the gap while the permanent search runs.

For board and executive appointments at larger firms, our sister practice Exec Capital runs FCA-regulated executive search at C-suite level, and we work together where a firm needs both an executive search and interim Senior Manager cover.

Common Mistakes

• Leaving responsibilities unallocated. Even for a short period, this is exactly what the regulator is concerned about.
• Relying on the 12-week rule for a foreseeable departure. The rule exists for unexpected or temporary absences, not as a substitute for planning.
• Overloading an existing Senior Manager. Temporary reallocation only works if the person has the time and expertise. Otherwise it creates a new risk.
• Late notifications. Missing the seven-business-day deadline for Form C is avoidable and creates an unnecessary issue with the supervisor.
• A thin handover. Incoming Senior Managers who inherit problems without being told about them are the most exposed, and the most likely to leave early themselves.

A 30-Day Checklist

• Day 1: list the departing holder’s functions, Prescribed Responsibilities and open matters.
• Week 1: agree the leaving date, start the handover document and brief the board.
• Weeks 1–2: decide interim cover and reallocate responsibilities, then update the Responsibilities Map.
• Week 2: speak to the supervisor where the role is significant.
• Weeks 2–4: review the role, agree the specification and start the search.
• By the leaving date: submit Form C within seven business days and any revised Statements of Responsibilities.

The Bottom Line

A Senior Manager’s resignation is manageable if the firm acts quickly and methodically. Know what’s leaving, decide who covers it, tell the regulator and start the search. Firms that do these things in the first month rarely have difficulty with the transition. Firms that wait usually do.