A Management Responsibility Map (MRM) is a firm-level document setting out how an SM&CR firm’s business is governed at the senior level. Where an individual’s Statement of Responsibilities (SoR) describes that individual’s accountability, the MRM describes the whole: how the Senior Manager population fits together, who reports to whom, and how every Prescribed Responsibility is covered.
Who needs an MRM
The MRM obligation applies to:
- Enhanced SM&CR firms: the largest and most complex FCA solo-regulated firms
- Dual-regulated firms: banks, building societies, insurers and large investment firms supervised by both the FCA and the PRA
Core SM&CR firms do not have a formal MRM obligation, but must maintain accurate and up-to-date SoRs for each Senior Manager.
What an MRM must show
An MRM typically covers:
- The firm’s overall governance structure: board, executive committee, and key management bodies
- Each SMF holder and the functions they perform
- How Prescribed Responsibilities are allocated across the SMF population
- The reporting lines between Senior Managers
- How key accountability areas of the business map to named individuals
The MRM must be internally consistent: it must align with each Senior Manager’s Statement of Responsibilities, and any change to an SoR must be reflected in the MRM. Where there is a conflict between the two, the firm has an accuracy problem that is itself a governance concern.
PS26/6 changes from April 2026
FCA Policy Statement PS26/6 introduced a batching permission for SoR and MRM submissions: solo and dual-regulated firms may now submit updated SoRs and MRM changes to the FCA every six months in a batch, rather than on each individual change. This reduces the administrative burden of continuous small updates.
The internal governance obligation is unchanged: internal records (the SoR itself and the MRM) must still be updated immediately when responsibilities change. The batching permission covers FCA submission, not internal governance. For the full picture of PS26/6’s reforms, see our guide to SM&CR reform 2026.