The Treasury has published a paper on extending the senior managers and certification regime (SM&CR) to all persons who are authorised under FSMA. It is intended that the SM&CR will replace the approved persons regime. The key features of the regime are: (i) an approval regime focused on senior management, with requirements on firms to submit robust documentation on the scope of these individuals' responsibilities; (ii) a statutory requirement for senior managers to take reasonable steps to prevent regulatory breaches in their areas of responsibility; (iii) a requirement on firms to certify as fit and proper any individual who performs a function that could cause significant harm to the firm or its customers, both on recruitment and annually thereafter; and (iv) a power for the regulators to apply enforceable rules of conduct to any individual who can impact their respective statutory objectives. The government intends to implement the extended SM&CR during 2018.