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Role Guide

Section 250: What Compliance Directors Need to Do Before June 29

As compliance director, the Section 250 gap analysis sits squarely on your desk. You need to identify every individual in your firm who falls within Section 250's scope but is not SM&CR-approved, send them declarations, and produce a PDF/A-3B board evidence pack (designed for business-record admissibility under CEA 1995 s.8–9) — all before June 29, 2026. This is not a risk you can escalate. Section 250 creates corporate attribution liability for which there is no good-faith defence.

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TL;DR

As compliance director, the Section 250 gap analysis sits squarely on your desk. You need to identify every individual in your firm who falls within Section 250's scope but is not SM&CR-approved, send them declarations, and produce a PDF/A-3B board evidence pack (designed for business-record admissibility under CEA 1995 s.8–9) — all before June 29, 2026. This is not a risk you can escalate. Section 250 creates corporate attribution liability for which there is no good-faith defence. CoverProof automates the SM&CR gap analysis, zero-login declarations, and PDF/A-3B board evidence pack generation that Compliance Directors need to complete before the June 29, 2026 statutory deadline under Section 250 of the Crime and Policing Act 2026.

Your Section 250 obligations

1

Run the gap analysis

Map every individual in a significant role against your SM&CR register. The gap — those in scope for Section 250 but not on the register — is your exposure list. You need this documented, not just known.

2

Send and receive declarations

Every individual in the gap must provide a Section 250 declaration before June 29. Declarations need to be timestamped, immutable, and traceable back to a specific analysis. A one-line email does not meet this standard.

3

Produce board evidence

Your board needs to be able to show that it identified the gap and acted before the deadline. The evidence pack must be PDF/A-3B compliant, hash-verifiable, and contain the declaration audit trail. This is what gives a court, regulator, or auditor the record it needs to evaluate what your firm did and when.

4

Handle counterparty obligations

If your firm relies on external counterparties — sub-advisers, introducers, outsource partners — you need written confirmation that they have completed their own Section 250 analysis. Their exposure is your risk.

Your pre-June 29 checklist

  • □Identify all individuals in significant roles (not just SMF holders)
  • □Cross-reference against your FCA register extract
  • □Flag everyone who is in scope but not approved
  • □Send declarations to all flagged individuals
  • □Track RAG status — chase outstanding declarations
  • □Confirm counterparty compliance for all significant third parties
  • □Generate and store the board evidence pack
  • □Brief the board and obtain sign-off
  • □Set calendar reminder for annual renewal

Common questions

What if an individual refuses to provide a declaration?

A refusal to declare is itself a significant risk indicator. Document the refusal, escalate to the board, and seek legal advice. CoverProof's audit trail records all declaration attempts, responses, and refusals — this is part of your evidence pack.

Do I personally face criminal liability as compliance director?

Section 250 creates liability for the firm and for individuals in scope. As a compliance director, your own SM&CR designation is relevant — but so is whether you have taken reasonable steps to identify and remediate the firm's exposure. A documented, timely gap analysis is your strongest evidential protection — prosecutors weigh compliance activity when deciding whether to proceed, but Section 250 provides no statutory safe harbour.

How long does the gap analysis take with CoverProof?

Import your SM&CR register extract (typically 5 minutes), and CoverProof's AI identifies your gap within 2 minutes. Sending declarations takes another 5 minutes. The entire initial cycle is under 30 minutes.

The fastest path from compliance director to board sign-off.

CoverProof walks you through every step: import, analyse, declare, evidence. Your board pack is generated automatically as declarations complete. First gap analysis is free — no contract required.

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