UK Enhanced SM&CR Firms
Hackford's analysis of 515 Enhanced SM&CR firms, covering firm types, scale, location, senior-management change and technology footprint.
What the report covers
Enhanced SM&CR firms are large or complex financial businesses that face additional rules around senior roles, accountability and compliance. The FCA does not publish a list of the population, making these firms difficult to examine as a whole.
Hackford has combined regulatory, corporate and financial signals to identify an estimated population of 515 Enhanced firms as at July 2026. The report examines firm type, registered-office location and legal-entity scale.
It also analyses changes in the individuals holding SMF16 Compliance Oversight and SMF24 Chief Operations. Nearly one in four firms with SMF16 active at both July snapshots had a different recorded holder in July 2026 from a year earlier.
The final section looks at live web technology detections across 393 unique websites associated with the population, ahead of the FCA's new operational-incident and material third-party reporting rules taking effect on 18 March 2027.
Dataset
The July 2026 dataset covers an estimated 515 Enhanced SM&CR firms. It includes firm type and registered-office location for the population, turnover data for 376 firms, employee data for 411 firms, current and historical Senior Management Function records, and public website-technology observations for 393 unique websites.
Key findings
- Hackford identified an estimated 515 Enhanced SM&CR firms as at July 2026.
- Investment management is the largest firm type, accounting for 189 firms, or 37% of the population.
- Fifty-eight per cent of firms have a registered office in London; Edinburgh and Birmingham are the next-largest locations.
- In 44% of firms with an active SMF16 Compliance Oversight function, the same person also holds SMF17 Money Laundering Reporting Officer.
- Among firms with SMF16 active at both July snapshots, 23.7% had a different recorded holder in July 2026 from July 2025.
- SMF24 recorded-holder change reached 44.4% in 2025 before falling to 32.9% in 2026.
- Across 393 unique websites, the median website produced 115 live web-technology detections and 58% produced at least 100.
Methodology
The FCA does not publish a list of Enhanced SM&CR firms. Hackford estimates the population by combining public signals including Enhanced-associated SMFs, CASS and other disclosures, service-line fees, turnover and fee income, assets under management, permissions and solo-regulated status.
The population is a July 2026 snapshot. It excludes firms with a current Prudential Regulation Authority regulator entry and should be read as Hackford's estimate rather than an FCA register.
Turnover percentages cover 376 firms and employee percentages cover 411 firms, using the latest available filed financial data at legal-entity level.
Senior-function change rates include firms where the relevant function was active at both July snapshots and compare the recorded holders at those points in time.
The website analysis deduplicates websites shared by more than one regulated entity and sums group-level live detections across detectable web technologies.
Who should read this
- Financial-services law firms advising Enhanced SM&CR firms
- Compliance consultancies, regtech providers and governance specialists
- Operational-resilience, cybersecurity and third-party risk teams
- Researchers and journalists covering FCA regulation and financial-services market structure
Definitions
- Enhanced SM&CR firm
- A solo-regulated firm subject to the Enhanced tier of the Senior Managers and Certification Regime because it meets the relevant criteria or has opted up.
- SMF16 Compliance Oversight
- The Senior Management Function responsible for the compliance function and reporting on compliance to the governing body, where the function applies.
- SMF24 Chief Operations
- The Enhanced Senior Management Function for the most senior person responsible for a firm's internal operations, systems and technology, where that role exists.
- Recorded-holder change
- A difference between the individuals recorded as holding a Senior Management Function at two consecutive July snapshots.
Report FAQ
Does the FCA publish a list of Enhanced SM&CR firms?
No. Firms are responsible for determining their SM&CR category and the FCA does not publish a definitive list of the Enhanced population. The report presents Hackford's estimate.
How many Enhanced SM&CR firms did Hackford identify?
Hackford identified an estimated 515 firms in the July 2026 population.
What does the SMF16 change figure measure?
It measures the share of firms with SMF16 active at both July snapshots where the individuals recorded as holding the function differed from the previous July.
When do the FCA's new third-party reporting rules take effect?
The new operational-incident reporting and material third-party notification and register requirements take effect on 18 March 2027.
Is the report endorsed by the FCA?
No. The report is an information resource produced by Hackford and is not endorsed by the FCA.
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Citation: Hackford, "UK Enhanced SM&CR Firms", July 2026.
- The 515-firm population is Hackford's estimate as at July 2026, not an FCA register.
- Financial measures are the latest available filed data and refer to legal entities rather than consolidated corporate groups.
- Senior-function observations are based on FCA Register records available for the report snapshot.
- Website observations describe technologies detectable through public websites.
- The report is an information resource only and is not endorsed by the FCA.