Why CoverProof asks you to confirm scope
Section 250 of the Crime and Policing Act 2026 attributes criminal offences of “senior managers” to the firm. The statutory definition in s.250(3) is a functional test: an individual who plays a significant role in making decisions about, or in the managing or organising of, the whole or a substantial part of the organisation’s activities.
Many of those individuals are not on the FCA Register. Acting executives, group-entity directors, heads of business lines with budget authority, and interim post-holders typically meet the functional test without holding an SMF approval. A gap analysis that covers only FCA-approved staff will miss the highest-risk exposures.
CoverProof can only classify the individuals you’ve uploaded. Before classification runs, the compliance officer must confirm that the uploaded register genuinely reflects the complete senior-manager population — not just the FCA-approved subset. This confirmation forms part of the audit trail and is reproduced verbatim in your board evidence pack.
What the four confirmations cover
The gate presents four checkboxes, each of which must be ticked before classification can proceed:
SMF holders confirmed
All individuals approved under SMF1–SMF29 for the firm are included — including SMF1 (CEO), SMF24 (Chief Operations Function), SMF27 (Partner Function), and SMF29 (Limited Scope Function) where applicable.
Certified persons and Conduct Rules staff confirmed
Everyone the firm has certified as fit and proper under the Certification Regime, plus the Conduct Rules population the firm relies on for this SM&CR register.
Unregistered senior employees confirmed
Anyone with material decision authority over a substantial part of the business — including acting post-holders, heads of business lines with budget authority, divisional managers with P&L control — whether or not they currently hold an SMF approval.
Group and parent entity executives confirmed
Any director or executive at a parent company, subsidiary, or appointed representative firm who exercises influence over this firm's regulated activities.
An optional free-text field allows you to record individuals you considered including but decided to exclude, and your reasoning. Documenting exclusion decisions strengthens the audit trail.
What happens if I cannot tick all four?
The classification job will not run until all four confirmations are recorded. This is intentional — a partial scope confirmation would undermine the evidentiary value of the gap analysis.
If you need to add individuals before confirming scope:
- Go back to the Import page and re-upload your SM&CR register CSV with the additional individuals included.
- A new upload re-opens the scope gate automatically, so you can re-confirm coverage for the updated register.
- Return to the gap analysis to complete the affirmation.
How the affirmation becomes part of your audit trail
When you submit the scope affirmation, CoverProof records:
- The identity of the compliance officer who submitted the affirmation
- The timestamp of submission (UTC, server clock)
- Which of the four confirmations were ticked
- Any exclusion notes entered
- The import ID of the register the affirmation applies to
This record is included verbatim in the board evidence pack — board members and the firm’s compliance function can see exactly what was confirmed, by whom, and when. The affirmation cannot be modified after submission; a re-upload creates a new import record and a new affirmation record.
Re-affirming scope after a register update
If your senior-manager population changes — new appointments, departures, structural changes — you should re-upload your SM&CR register to reflect the updated population. Each upload triggers a new scope gate, so you re-affirm scope against the new register. This keeps the audit trail current and ensures the classification reflects your firm’s actual position.
Previous affirmations are retained in the audit trail. The board evidence pack always shows the affirmation that corresponds to the register version used for that pack.