What are FCA regulatory references and who must request them?
Under the Senior Managers and Certification Regime, some finance hires need references in a set format. Here is how that sits alongside ordinary references.
What are FCA regulatory references?
FCA regulatory references are references that regulated firms must request under SYSC 22 of the FCA Handbook before appointing senior managers, certified staff and some board directors. The hiring firm asks the current employer and anyone who employed the person in the past six years. Former employers give them in a set template. RefAssure handles ordinary employment references, not the regulatory template.
How FCA regulatory references work
The Senior Managers and Certification Regime (SM&CR) applies to firms regulated by the Financial Conduct Authority, and by the Prudential Regulation Authority for dual-regulated firms. The reference rules are in chapter 22 of the Senior Management Arrangements, Systems and Controls sourcebook (SYSC 22) in the FCA Handbook.
When a firm must request one
- Before appointing someone to perform a senior management or other controlled function.
- Before issuing a certificate to someone under the certification regime, including renewals.
- For certain firms, before appointing a non-executive board director.
Who it asks, and how far back
The hiring firm must take reasonable steps to get references from the candidate's current employer and from anyone who employed them in the past six years. The firm giving the reference must use the template in the Handbook and disclose relevant matters from the past six years, such as breaches of conduct rules and disciplinary action. Serious misconduct must be disclosed whenever it happened. The giving firm must respond as soon as reasonably practicable, and must update a reference it gave if something relevant comes to light later.
Rules are changing
The FCA, PRA and HM Treasury are reforming the SM&CR in phases through 2026. Before you rely on any detail, check the current SYSC 22 text in the FCA Handbook.
Where agencies fit
The duty to obtain a regulatory reference sits with the regulated firm, not the recruiter. Agencies placing into financial services usually help by gathering a full six-year employment history early, flagging gaps, and collecting ordinary references that the firm can use alongside its own regulatory reference requests.
Regulatory reference vs employment reference.
| FCA regulatory reference | Employment reference | |
|---|---|---|
| Who it applies to | Senior managers, certified staff and some board roles at regulated firms | Any hire, any sector |
| Who must request it | The hiring regulated firm | The employer or the agency |
| Period covered | Past six years of employment | Whatever period you choose |
| Format | Set template in the FCA Handbook | Your own questions |
| Where RefAssure helps | Not the regulatory template | Consent, chasing and a signed PDF |
What finance employment references should ask.
Alongside the regulatory reference, an ordinary reference can cover what the template does not.
Exact dates and role
So the six-year history lines up month by month.
Conduct and integrity
How they handled clients, conflicts and confidential information.
Performance
Rate their capability in the role on a 1 to 10 scale.
Re-employment
Would the referee employ them again, yes or no?
Ordinary references, handled for you.
RefAssure collects consent, chases referees and files a signed PDF, so your team can focus on the regulatory steps.
- Upload your own reference form as a PDF or Word file and check it before use
- 5 emails and up to 2 texts over 12 days
- Timestamps for consent, requests, reminders and completion
- UK data hosting, unlimited team members
FCA regulatory reference questions
More in the full FAQs.
How many years does an FCA regulatory reference cover?
The hiring firm must request references from employers in the past six years. The firm giving the reference discloses relevant matters from that period, and serious misconduct regardless of when it happened.
Does a recruitment agency have to request regulatory references?
No. The duty sits with the regulated firm making the appointment. Agencies often help by gathering the employment history and ordinary references early.
Can RefAssure send the FCA regulatory reference template?
RefAssure is built for ordinary employment references with your own questions. The regulatory reference has a set template and its own rules, so your compliance team should handle it directly.
Is there a deadline for giving a regulatory reference?
SYSC 22 says the giving firm must provide it as soon as reasonably practicable. Check the Handbook for the current wording.
What other checks do finance hires need?
Depending on the role, criminal record checks, credit checks and fitness and propriety assessments. RefAssure does not do these. See pre-employment checks and our DBS checks guide.
How much does an employment reference cost with RefAssure?
Your first reference is free, then credits cost from 99p down to 80p with no monthly fee and no VAT added. See pricing.
Related guides
Leave the chasing to RefAssure.
Your first reference is free. Consent, reminders and a signed PDF included.