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 FCA has three months to decide an application to approve a senior manager, counted from the day it receives a complete one. If an approved director, partner or compliance officer leaves without warning, someone else can cover for up to 12 weeks without approval, and since 24 April 2026 that cover lasts until the FCA decides, provided the application goes in within the 12 weeks.

The periods, and where each one starts and stops

In a small advice firm or mortgage broker the approved functions are usually executive director (SMF 3) or partner (SMF 27), compliance oversight (SMF 16) and money laundering reporting (SMF 17). The firm's entry on the Financial Services Register shows who holds each.

How long the FCA takes in practice

The FCA's page on assessing applications says: "We must decide on an application within 3 months of receiving it." Its service metrics for January to March 2026 show what happened to applications from authorised firms under the regime.

The FCA says complete applications are more likely to meet the target, and SUP 10C.10.27G warns that an incomplete one takes longer than the published times.

What changed on 24 April 2026

The 12-week rule moved to a new section of the Handbook, SUP 10C.3A, and its effect changed. The FCA's policy statement PS26/6 describes it as a change "to allow firms 12 weeks to submit" an application "rather than 12 weeks to submit & receive approval". Under the old wording a firm needed the approval itself inside the 12 weeks.

Three conditions come with the cover.

1. The absence must be temporary or reasonably unforeseen. The FCA's own table of examples says a retirement agreed a year ahead does not qualify, and neither does the end of a fixed-term contract.
2. The firm must make sure the person covering is fit and proper for the role (SUP 10C.3A.13R).
3. The absent manager's prescribed responsibilities go to another approved senior manager. They cannot go to the person covering unless that person is approved too (SUP 10C.3A.20G).

One firm's dates

A firm has two directors. One holds the compliance oversight function. She resigns without warning and stops work on Monday 5 October 2026. A senior paraplanner covers the function from that day.

If the FCA asks a question on 16 November and has the full answer on 23 November, the clock is paused for seven days and the last date becomes Monday 8 February 2027.

The 12 weeks are counted across a 12-month period. In the FCA's example, a firm that used ten weeks of cover with one person can use only two more with a second.

On the day a senior manager goes

1. Write down the date the person stopped performing the function. Every period runs from it.
2. Appoint the cover in writing, record why the person is fit and proper, and move the prescribed responsibilities to an approved senior manager.
3. Diarise ten business days for Form C, and week 12.
4. Decide who the applicant is and submit a complete application as early as you can. SUP 10C.3A.16G expects firms to apply "as soon as reasonably possible".
5. Answer any FCA question the day it arrives. The clock is stopped until you do.

A change of director also changes who signs. The governing body approves the Consumer Duty board report, a named senior manager answers for any AI tool under our six conditions for client data, and someone must still hold the eight-week complaint clock. What the firm pays the regulator each year is in our guide to FCA fees and the FSCS levy.

The adviser, and compliance where the firm's procedures require it, reviews and signs anything a tool drafts, and that includes an application form. This page is general information, not legal, regulatory or financial advice.