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SYSC 25.4 Guidance about what should be in a management responsibilities map

Material applicable to all firms

SYSC 25.4.1G
SYSC 25.4.2G

1The statements of responsibilities and the management responsibilities map should all be prepared in a way that makes it simple to see how the responsibilities allocated in a particular statement of responsibilities fit into the overall system of management and governance of the firm.

SYSC 25.4.3G

1The management responsibilities map should include functions that are:

  1. (1)

    included in a PRA controlled function under the PRA rules complementing SUP 10C.9 (Minimising overlap with the PRA approved persons regime) (as listed in SUP 10C.9.6G(2));

  2. (2)

    excluded from the other overall responsibility function under SUP 10C.7.1R(2) (Exclusion for approved person with approval to perform other designated senior management functions); or

  3. (3)

    excluded from the other local responsibility function under SUP 10C.8.1R(2) (Exclusion for approved person with approval to perform other designated senior management functions).

SYSC 25.4.4G

1A firm’s management responsibilities map should demonstrate that there are no gaps in the allocation of responsibilities among its management.

SYSC 25.4.5G

1A firm need only include summary details of the persons in SYSC 25.2.3R(1).

SYSC 25.4.6G

1A firm’s SMF managers and members of its governing body may overlap with its senior management and senior personnel. If so, the firm does not have to give the same details twice.

SYSC 25.4.7G

1A firm should include details about individuals in addition to the details in SYSC 25.2.3R(1), (3) and (5) if they are needed to make the management responsibilities map clear. For example, if the same individual has responsibilities in a number of different areas of the firm it may be necessary to make this clear.

SYSC 25.4.8G

1A firm should only include summary details about statements of responsibilities under SYSC 25.2.3R(2). There is no need to duplicate the statements of responsibilities. The main aim of including material about statements of responsibilities in the management responsibilities map is to show how that material:

  1. (1)

    fits into the firm’s overall governance structure; and

  2. (2)

    for each statement of responsibilities, fits with the others.

SYSC 25.4.9G

1A management responsibilities map should include a checklist confirming that all FCA-prescribed senior management responsibilities have been allocated or, if some have not been allocated, the reason why.

SYSC 25.4.10G


  1. (1)

    any designated senior management function is performed by; or

  2. (2)

    any FCA-prescribed senior management responsibility is allocated to;

more than one person, a firm’s management responsibilities map should give details of how the performance or discharge of the responsibilities is to be carried out by those persons.

SYSC 25.4.11G

1The executive director function, the other local responsibility function, the group entity senior manager function,2 the partner function and the other overall responsibility function are defined generally and generically and can be performed by several people. Therefore, there is no need to explain why several people perform one of the functions.

SYSC 25.4.12G

1The material in SUP 10C.11.31G and SUP 10C.11.32G (recording sharing and splitting of responsibilities in statements of responsibilities) also applies to a management responsibilities map.

SYSC 25.4.12AG

3In relation to the temporary absence of an SMF manager of a firm see the guidance at SUP 10C.14.5JG.

Branches of overseas firms

SYSC 25.4.13G

1One effect of SYSC 25.1.5R is that an overseas SMCR firm should draw up its management responsibilities map as if the rest of the firm outside the UK branch were a separate company in its group. This means, for example, that the map should include:

  1. (1)

    details of how the branch’s management and governance arrangements fit together with the wider firm;

  2. (2)

    details of the extent to which the branch’s management and governance arrangements are provided by, or shared with, the wider firm; and

  3. (3)

    details of the reporting lines and the lines of responsibility between the branch and those who carry out functions in relation to it and the wider firm and persons acting for it.

Small firms

SYSC 25.4.14G
  1. (1)

    1The FCA expects that the management responsibilities map of a small and non-complex firm is likely to be simple and short. It may be no more than a single sheet of paper.

  2. (2)

    See SYSC 24.3.5G for what small and non-complex mean.