Can someone cover a senior manager who is leaving or away? Four questions on the 12-week rule

A director, partner or compliance officer at an advice firm or mortgage broker has resigned, fallen ill or is going on leave, and someone else needs to hold the function. Whether they can do so without FCA approval, and for how long, turns on four things: whether the manager is leaving or away, whether the firm saw it coming, who is covering, and whether an application has gone in. This questionnaire asks up to four questions and gives one of seven outcomes, each with the rule behind it. It follows SUP 10C.3A as in force from 24 April 2026 and section 61 of FSMA, read on 2 October 2026.

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Senior manager leaving or away: can someone cover

Answer each question. Some questions appear only when an earlier answer makes them relevant. Nothing you choose leaves this page.

1. Is the senior manager leaving the firm for good, or away for a time?ChooseLeaving for good, or has stopped performing the functionAway for a time: illness, leave or holiday
2. Could the firm reasonably have seen this coming, and for how long?ChooseNo: it came without warning (resignation, illness, an accident)Yes, a planned absence of under 12 weeks, such as a holidayKnown well ahead: a planned exit or an absence over 12 weeks
3. Is the person who will cover already one of the firm's staff to whom the conduct rules apply?ChooseYes, already on the firm's staff and under the conduct rulesNo, an outside consultant or someone not yet on the staff
4. Has a complete application been made for someone to take the function, and when?ChooseYes, made within 12 weeks of the day the manager stoppedNot yet, and the 12 weeks have not run outNo, and 12 weeks have passed since the manager stopped

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The outcome is the rule as our guides and the sources named set it out, applied to the answers you gave. It is not advice on your own case. Regulated work: the adviser, and the compliance function where the firm's procedures require it, reviews and signs every client-facing document and every suitability decision; the AI assistant prepares, checks and chases, it never advises.

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The questions, and why each is asked

1. Is the senior manager leaving the firm for good, or away for a time? SUP 10C.3A covers both a temporary absence and a departure. A departure needs Form C within ten business days (SUP 10C.14.5R); an absence over 12 weeks needs Form D (SUP 10C.14.5ER).

2. Could the firm reasonably have seen this coming, and for how long? SUP 10C.3A.6R allows cover only for an absence that is temporary or reasonably unforeseen, and SUP 10C.3A.8R extends it only where the absence, or its running past 12 weeks, was not foreseen.

3. Is the person who will cover already one of the firm's staff to whom the conduct rules apply? SUP 10C.3A.6R(1) lets the firm appoint only a member of its conduct rules staff, and SUP 10C.3A.13R requires the firm to make sure that person is fit and proper for the role.

4. Has a complete application been made for someone to take the function, and when? Under SUP 10C.3A.8R a valid and complete application made before the 12 weeks expire extends the cover until the FCA finally determines it. One made later does not. This question appears only when an earlier answer makes it relevant.

Every outcome, and the rule behind it

The rule cannot be used: the person covering needs approval first

Reached when: "Is the person who will cover already one of the firm's staff to whom the conduct rules apply?" answered "No, an outside consultant or someone not yet on the staff".

SUP 10C.3A.6R lets a firm put a member of its conduct rules staff into a senior manager's function without approval, for less than 12 weeks in a consecutive 12-month period. Someone outside that group has no such cover and needs FCA approval before performing the function. Section 61(3A) of FSMA gives the FCA three months from receipt to decide; its target is two months for 95% of cases, and in January to March 2026 the median decision took 19 days.

• Choose cover from the firm's own staff if someone suitable is there, and record why they are fit and proper.
• Otherwise submit a complete application for the outside candidate before they take on the function.
• Move the absent manager's prescribed responsibilities to another approved senior manager in the meantime.

Source: FCA Handbook SUP 10C.3A.6R and 10C.3A.13R (FCA 2026/17, in force 24 April 2026, printed in PS26/6); FSMA section 61(3A) on legislation.gov.uk; FCA Authorisations operating service metrics 2025/26 Q4; each read on 2 October 2026. The working is in How long does FCA approval of a senior manager take, and how long can someone cover without it? Three months in law, 12 weeks of cover, and the dates for one advice firm.

Seen coming and long: get the replacement approved before the manager goes

Reached when: "Could the firm reasonably have seen this coming, and for how long?" answered "Known well ahead: a planned exit or an absence over 12 weeks".

A planned exit is neither temporary nor unforeseen, so SUP 10C.3A.6R gives no cover for it: the FCA's examples in SUP 10C.3A.12G rule out a retirement agreed a year ahead and the end of a fixed-term contract. A long absence known in advance can use the 12 weeks but not the extension in SUP 10C.3A.8R, and the FCA's parental leave example expects the replacement to be approved before the leave starts. Section 61(3A) of FSMA gives the FCA three months from receipt to decide.

• Pick the replacement during the notice period and submit a complete application at once.
• Count back three months from the leaving or leave date: apply before then to be safe.
• Keep a current succession plan for each senior manager, as SUP 10C.3A.16G expects.

Source: FCA Handbook SUP 10C.3A.6R, 10C.3A.8R, 10C.3A.12G and 10C.3A.16G (FCA 2026/17, in force 24 April 2026, printed in PS26/6); FSMA section 61(3A) on legislation.gov.uk; each read on 2 October 2026. The working is in How long does FCA approval of a senior manager take, and how long can someone cover without it? Three months in law, 12 weeks of cover, and the dates for one advice firm.

A planned short absence: cover for under 12 weeks, ending at the return

Reached when: "Could the firm reasonably have seen this coming, and for how long?" answered "Yes, a planned absence of under 12 weeks, such as a holiday".

SUP 10C.3A.6R lets a member of the firm's conduct rules staff cover a temporarily absent senior manager without approval for less than 12 weeks in a consecutive 12-month period, and SUP 10C.3A.10G ends the cover no later than the manager's return. The 12 weeks are counted across the year: in the FCA's own example, ten weeks of cover leaves two. No form is due for an absence under 12 weeks; once an absence passes 12 weeks, Form D is due within seven business days (SUP 10C.14.5ER).

• Appoint the cover in writing with the start date and the expected return date.
• Keep a running total of the weeks of cover used for that function in the last 12 months.
• If the absence runs on unexpectedly, answer this questionnaire again as a sudden absence.

Source: FCA Handbook SUP 10C.3A.6R, 10C.3A.10G and 10C.3A.12G (FCA 2026/17, in force 24 April 2026, printed in PS26/6) and SUP 10C.14.5ER, read on 2 October 2026. The working is in How long does FCA approval of a senior manager take, and how long can someone cover without it? Three months in law, 12 weeks of cover, and the dates for one advice firm.

The 12 weeks ran out with no application: the cover has ended

Reached when: "Has a complete application been made for someone to take the function, and when?" answered "No, and 12 weeks have passed since the manager stopped".

SUP 10C.3A.6R covers the temporary replacement for less than 12 weeks in a consecutive 12-month period, and SUP 10C.3A.8R extends that only where a valid and complete application went in before the 12 weeks expired. In the FCA's own example in SUP 10C.3A.12G, an application made more than 12 weeks after the cover began does not get the extended period. Once the 12 weeks have gone, the person covering has no exemption and the function needs an approved holder.

• Give the function today to an approved senior manager if the firm has one.
• Submit a complete application for the replacement now: section 61(3A) of FSMA gives the FCA three months.
• Record what happened and ask compliance whether it has to be reported to the FCA.

Source: FCA Handbook SUP 10C.3A.6R, 10C.3A.8R and 10C.3A.12G (FCA 2026/17, in force 24 April 2026, printed in PS26/6); FSMA section 61(3A) on legislation.gov.uk; each read on 2 October 2026. The working is in How long does FCA approval of a senior manager take, and how long can someone cover without it? Three months in law, 12 weeks of cover, and the dates for one advice firm.

Application made inside the 12 weeks: cover runs until the FCA decides

Reached when: "Has a complete application been made for someone to take the function, and when?" answered "Yes, made within 12 weeks of the day the manager stopped".

Since 24 April 2026 SUP 10C.3A.8R extends the cover until the application is finally determined, provided a valid and complete one was made before the 12 weeks expired: until the FCA grants it, the firm withdraws it, or a refusal can no longer be taken to the Tribunal. Section 61(3A) of FSMA gives the FCA three months from receipt, and it may stop the clock to ask for information. Its target is two months; in January to March 2026 the median decision took 19 days.

• Answer any FCA question the day it arrives: the clock is stopped until the full answer is in.
• Diary three months from the date the FCA received the application.
• Check Form C went within ten business days of a departure, or Form D within seven business days of 12 weeks' absence.
• If the manager who left approved the Consumer Duty board report, record who on the governing body approves the next one.

Source: FCA Handbook SUP 10C.3A.8R (FCA 2026/17, in force 24 April 2026, printed in PS26/6), SUP 10C.14.5R and 10C.14.5ER; FSMA section 61(3A); FCA, How we assess senior management function applications (last updated 27 March 2026); FCA Authorisations operating service metrics 2025/26 Q4; each read on 2 October 2026. The working is in The Consumer Duty annual board report for a small advice firm.

A sudden departure: cover can start now, apply within 12 weeks

Reached when: "Has a complete application been made for someone to take the function, and when?" answered "Not yet, and the 12 weeks have not run out"; "Is the senior manager leaving the firm for good, or away for a time?" answered "Leaving for good, or has stopped performing the function".

SUP 10C.3A.6R lets a member of the firm's conduct rules staff cover a senior manager who left without warning, without approval, for less than 12 weeks in a consecutive 12-month period. The 12 weeks run from the day the manager stopped performing the function: from Monday 5 October 2026 they end on Sunday 27 December 2026. A complete application made before then keeps the cover going until the FCA decides (SUP 10C.3A.8R). Form C is due within ten business days (SUP 10C.14.5R): by Monday 19 October 2026.

• Appoint the cover in writing and record why that person is fit and proper (SUP 10C.3A.13R).
• Send Form C within ten business days of the day the manager stopped.
• Submit a complete application as soon as reasonably possible, and well before week 12.

Source: FCA Handbook SUP 10C.3A.6R, 10C.3A.8R and 10C.3A.13R (FCA 2026/17, in force 24 April 2026, printed in PS26/6) and SUP 10C.14.5R, read on 2 October 2026. The working is in How long does FCA approval of a senior manager take, and how long can someone cover without it? Three months in law, 12 weeks of cover, and the dates for one advice firm.

A sudden absence: cover for up to 12 weeks, ending when the manager returns

Reached when: any other set of answers.

SUP 10C.3A.6R lets a member of the firm's conduct rules staff cover an unforeseen absence without approval for less than 12 weeks in a consecutive 12-month period, and SUP 10C.3A.10G ends that cover no later than the manager's return. If the absence may run past 12 weeks, a complete application for someone to perform the function, made before the 12 weeks expire, extends the cover until the FCA decides (SUP 10C.3A.8R). Form D is due within seven business days of the end of 12 weeks' absence, and again of the return.

• Appoint the cover in writing and record why that person is fit and proper (SUP 10C.3A.13R).
• Diary week 8 to decide whether an application is needed, and week 12 for Form D.
• Move the absent manager's prescribed responsibilities to another approved senior manager.

Source: FCA Handbook SUP 10C.3A.6R, 10C.3A.8R, 10C.3A.10G and 10C.3A.13R (FCA 2026/17, in force 24 April 2026, printed in PS26/6) and SUP 10C.14.5ER, read on 2 October 2026. The working is in How long does FCA approval of a senior manager take, and how long can someone cover without it? Three months in law, 12 weeks of cover, and the dates for one advice firm.

How to use the result

Use it on the day the manager stops, and again at week eight if no application has gone in. Every period in the outcomes runs from the date the manager stopped performing the function, so write that date down first. SUP 10C.3A.15G expects the rule to be used only when needed and for as short a time as reasonably possible, so treat 12 weeks as the outer limit, not the plan. Our guide to how long approval takes puts every date for one firm in a table.

The outcome applies the rule to the answers given; it cannot see the facts behind them. Where an answer is a judgement, or the facts are unusual, the outcome may not fit. The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and this page is general information, not regulatory or financial advice.

Overlyft sets up AI assistants for financial advisers and mortgage brokers: they prepare drafts for a person to approve. None of these outcomes depends on them.