Plain-English guides on Section 250 of the Crime and Policing Act 2026, SM&CR obligations, and compliance evidence standards for FCA-regulated firms.
Whether someone is a senior manager under Section 250 has nothing to do with their job title or whether the FCA approved them. It turns on a functional test in s.250(3). This guide applies that test to the roles a gap analysis most often gets wrong: the CTO, the COO, the divisional head, and the interim executive nobody put on the register.
A firm facing an offence attributed to it under Section 250 of the Crime and Policing Act 2026 will need a contemporaneous record of what it knew, what it did, and when. "We had a policy" is not enough. Documentary evidence of action is. This guide walks through what that evidence has to look like to hold up in 2027 or 2028.
The most common Section 250 misreading we see is "we are SM&CR-compliant, so we are Section 250-compliant". The statute does not say that. Section 250(3) defines a senior manager by what they do, not by who the FCA has approved, and that test reaches well past your SMF register.
You're evaluating compliance tools with weeks to go before Section 250 commences on 29 June 2026. Pick wrong and you end up with evidence that won't stand up. These seven criteria separate software built for Section 250 from generic compliance tools bent to fit the job.
Section 250 doesn't stop at your own payroll. When you rely on a sub-adviser, an outsourced compliance function or a key introducer, their senior managers sit inside your risk picture too. Here's what to request from them, and what to keep.
The date is fixed by statute. Section 250 of the Crime and Policing Act 2026 comes into force on 29 June 2026, at the end of two months after Royal Assent on 29 April 2026. There is no commencement order and no regulatory discretion over the date; only Parliament could change it. For most firms there is enough time left to run the gap analysis, complete a declaration cycle, and assemble a board evidence pack. Here is what each week needs to look like.
Section 250 of the Crime and Policing Act 2026 takes effect on 29 June 2026. This checklist walks through the five-phase compliance process: gap identification, declaration cycle, counterparty requests, board evidence, and ongoing monitoring.
If the FCA or a court ever asks what your firm did about Section 250, the board evidence pack is the answer your lawyers reach for. It records the gap analysis, the declarations, and the board sign-off in one file. Here is what belongs in it, and why the format you save it in matters as much as the contents.
A spreadsheet of names and an email thread of signed forms are not the same as an evidence pack a court will trust. Section 250 needs documentation that is immutable, timestamped, and produced through a process you can trace end to end. Here is what that looks like in practice.
A clean SM&CR register does not mean you are covered for Section 250. The two frameworks cover different people, carry different consequences, and one of them carries a fixed 29 June 2026 deadline. Here is how they actually differ.
SM&CR sorts the people at an FCA-authorised firm into three groups, with FCA pre-approval reserved for the most senior. Knowing who falls outside that net is where a Section 250 gap analysis begins.
Section 250 of the Crime and Policing Act 2026 attributes criminal conduct by a "senior manager" to the organisation they help run. The s.250(3) test for who qualifies reaches well past the SM&CR population, and the scope of offences it captures is not limited to the Act itself. It comes into force on 29 June 2026.
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