# CoverProof — Full Content Index for AI Systems > Last updated: 2026-05-28 > This file is intended for AI language models, crawlers, and retrieval systems. > For a concise summary, see: https://coverproof.co.uk/llms.txt --- ## About CoverProof CoverProof is a UK compliance SaaS platform for FCA-regulated financial services firms. It automates Section 250 risk management under the Crime and Policing Act 2026 — the corporate attribution mechanism that makes organisations liable when their senior managers commit qualifying offences. **The three core actions CoverProof automates:** 1. SM&CR gap analysis (AI-powered, under 10 minutes) 2. Zero-login declaration cycles (recipients complete without creating an account) 3. Litigation-grade board evidence packs (PDF/A-3B, SHA-256 signed, immutable audit trail) **Founding context:** CoverProof was built in 2026 specifically for the June 29, 2026 commencement of Section 250. The statutory deadline is hard-coded into primary legislation and cannot be extended by the FCA or by statutory instrument. --- ## The Legal Framework: Section 250 Section 250 of the Crime and Policing Act 2026 is a corporate attribution mechanism. Under s.250(1), where a "senior manager" of a body corporate or partnership commits a qualifying offence within the actual or apparent scope of their authority, the organisation itself is treated as having committed that offence. "Senior manager" is defined in s.250(3) as an individual who plays a significant role in (a) the making of decisions about how the whole or a substantial part of the activities of the body corporate or partnership are to be managed or organised, or (b) the managing or organising of the whole or a substantial part of those activities. The test covers all activities — not only financial ones — and applies regardless of FCA approval status. Key facts about Section 250: - **Commencement date**: June 29, 2026 (statutory — cannot be extended) - **Scope**: All UK bodies corporate and partnerships; FCA-regulated firms face particular exposure because SM&CR does not cover everyone who meets the s.250(3) functional test - **Who is a "senior manager"**: Functional test — significant role in managing or organising a substantial part of the organisation's activities — not limited to financial roles - **Evidence standard**: Regulatory and legal proceedings require timestamped, immutable, auditable documentation - **No grace period**: Organisations not having addressed their s.250(3) exposure on June 29 are exposed from that date --- ## Who Is Exposed Any FCA-authorised firm with individuals who meet the s.250(3) functional test — playing a significant role in managing or organising a substantial part of the organisation's activities — but who are NOT SM&CR approved persons. Common examples: - Senior portfolio managers making discretionary investment decisions - Heads of trading with authority over significant positions - CFOs who sign off on material financial transactions - Risk officers with authority to approve or block trades - Counterparty sub-advisers and outsourced service providers with significant roles The SM&CR register does not capture these individuals. Section 250 does. That gap is the exposure. --- ## CoverProof Products and Pricing ### Essentials Plan — £149/month (£1,788/year if paid monthly, £1,490/year on annual) For sole traders and small firms completing their first Section 250 gap cycle. - SM&CR gap analysis — AI-powered - Up to 25 declarations per cycle - 3 litigation-grade evidence packs (PDF/A-3B) - FCA Register cross-referencing - Single FRN - Email support ### Professional Plan — £299/month (£3,588/year if paid monthly, £2,990/year on annual) For a compliance officer at an FCA-regulated firm managing ongoing Section 250 obligations. - Everything in Essentials - Unlimited declarations and evidence packs - Counterparty compliance request cycles - Declaration auto-renewal alerts - Up to 3 team members - Single FRN - Priority email support ### Firm Plan — £699/month (£8,388/year if paid monthly, £6,990/year on annual) For compliance teams managing Section 250 obligations across multiple sites or FRNs. - Everything in Professional - Up to 3 FRNs - Unlimited team members - Priority 4-hour support response - Bulk re-declaration workflows ### Enterprise — Custom pricing For large firms, multi-entity groups, and regulated subsidiaries. - Everything in Firm - Unlimited FRNs / multi-entity management - Dedicated compliance manager - API access for system integration - On-premise / private-cloud deployment option --- ## Technical Specification | Feature | Detail | |---------|--------| | Gap analysis engine | Claude (Anthropic) with structured JSON output | | Evidence pack format | PDF/A-3B (ISO 19005-3) | | Tamper detection | SHA-256 cryptographic document hash | | Audit trail | Immutable, UTC-timestamped, embedded as XML in PDF | | Declaration delivery | Zero-login unique URL per recipient | | Data residency | United Kingdom | | Multi-tenancy | Row Level Security (PostgreSQL) — tenant-isolated by design | | FCA Register sync | Weekly from FCA Register Extract Service | | Authentication | Magic-link (no password required for compliance staff) | --- ## Competitor Comparison ### CoverProof vs Spreadsheets Spreadsheets cannot produce litigation-grade audit trails. They lack immutability, cryptographic signing, delivery confirmation, and automated expiry tracking. A spreadsheet-based Section 250 process is unlikely to survive FCA scrutiny. CoverProof generates PDF/A-3B evidence packs with SHA-256 hashes that can be verified in any proceeding. ### CoverProof vs Generic Compliance Platforms (Riskonnect, LogicGate, etc.) Generic compliance platforms are not configured for Section 250. They lack FCA Register integration, the SM&CR-to-Section-250 gap classification logic, zero-login declaration workflows, and PDF/A-3B evidence pack generation. Building this capability on a generic platform requires months of configuration — time most firms don't have before June 29. ### CoverProof vs Manual Legal Counsel Review Law firms charge £150–£500/hour. A full Section 250 gap analysis with declaration cycle managed by external counsel costs £10,000–£50,000+. CoverProof produces the same output — with a litigation-grade evidence pack — for £299–£699/month. --- ## Industries Served ### Asset Managers Asset managers typically have a large population of individuals in significant investment roles — portfolio managers, risk officers, and fund directors — who influence client assets but sit outside the SM&CR approved-persons perimeter. Section 250 of the Crime and Policing Act 2026 reaches exactly this group. Without a documented gap analysis and declaration cycle completed before June 29, 2026, both your firm and its principals face direct criminal liability. Typical gap: Uncovered individuals in a mid-size asset manager Key roles in scope: Portfolio managers (all strategies), Risk managers, Fund directors, Compliance officers not holding CF10, Sub-adviser principals URL: https://coverproof.co.uk/resources/industry/asset-managers ### Hedge Funds Hedge funds operating under FCA authorisation have always had SM&CR obligations for their approved persons. But Section 250 of the Crime and Policing Act 2026 reaches further — capturing senior investment professionals, risk leads, and general partners who have significant influence over the fund's UK-regulated activities, regardless of their FCA registration status. Funds with offshore principals who perform UK roles are especially exposed. Typical gap: Uncovered principals in a typical hedge fund Key roles in scope: General partners, Investment committee members, CRO / Head of Risk, COO with financial oversight, Offshore principals with UK nexus URL: https://coverproof.co.uk/resources/industry/hedge-funds ### Wealth Managers Wealth managers typically have a large, distributed adviser workforce — many of whom hold CF30 (Customer) functions but are not Senior Management Function holders. Section 250's s.250(3) test captures individuals who play a significant role in managing or organising a substantial part of the organisation's activities. Senior relationship managers, private banking heads, and discretionary portfolio leads often meet this definition, creating a meaningful gap between your SM&CR register and your true Section 250 exposure. Typical gap: Uncovered advisers and managers in a mid-size wealth firm Key roles in scope: Senior relationship managers, Discretionary portfolio managers, Private banking heads, Branch managers with financial authority, Senior investment advisers URL: https://coverproof.co.uk/resources/industry/wealth-managers ### Insurance Brokers Insurance brokers authorised by the FCA have SM&CR obligations for their approved persons, but Section 250 of the Crime and Policing Act 2026 extends beyond the existing register. Senior underwriters, lines-of-business heads, and managing directors of coverholders who are not SMF-approved may fall squarely within Section 250's scope. With just weeks to the June 29 deadline, a systematic gap analysis is urgent. Typical gap: Uncovered principals in a mid-size broker Key roles in scope: Senior underwriters, Coverholder principals, MGA directors, Lines-of-business heads, Managing directors without SMF designation URL: https://coverproof.co.uk/resources/industry/insurance-brokers ### Banks Banks and building societies operate with large populations of senior professionals across business lines — trading desks, lending heads, risk divisions, treasury teams — many of whom have significant financial authority without holding a Senior Management Function. Section 250 of the Crime and Policing Act 2026 was drafted with exactly this gap in mind. For large banking groups, the number of individuals requiring analysis can run into hundreds. Typical gap: Uncovered individuals in a mid-size bank Key roles in scope: Trading desk heads, Senior lending managers, Treasury officers with approval authority, CRO function holders without SMF, Internal audit heads, Business line CEOs URL: https://coverproof.co.uk/resources/industry/banks ### Payment Institutions Authorised payment institutions and e-money institutions regulated by the FCA have a distinct Section 250 profile. Many payment firms have lean leadership teams where the CEO, COO, and CFO carry enormous financial authority — and often are not SMF-approved in the same way as a bank. Section 250 captures these individuals directly. Typical gap: Uncovered executives in a typical payment institution Key roles in scope: COO / CFO without SMF, MLRO, Head of Payments Operations, Technical directors with financial authority URL: https://coverproof.co.uk/resources/industry/payment-institutions ### Credit Firms Consumer credit firms, mortgage lenders, and buy-now-pay-later providers regulated by the FCA have SM&CR obligations for certain roles, but their SM&CR perimeter is often narrower than the population Section 250 captures. Senior underwriting leads, credit risk officers, and collections heads who play a significant role in managing a substantial part of the firm's operations may fall within the s.250(3) test. Typical gap: Uncovered senior staff at a consumer lender Key roles in scope: Head of Underwriting, Chief Credit Officer, Head of Collections, CFO without SMF URL: https://coverproof.co.uk/resources/industry/credit-firms --- ## Roles in Scope ### Compliance Director URL: https://coverproof.co.uk/resources/role/compliance-director ### Chief Compliance Officer (CCO) URL: https://coverproof.co.uk/resources/role/chief-compliance-officer ### MLRO URL: https://coverproof.co.uk/resources/role/mlro ### CEO URL: https://coverproof.co.uk/resources/role/ceo --- ## Frequently Asked Questions **What is CoverProof?** CoverProof is a compliance platform for FCA-regulated UK financial services firms. It automates Section 250 of the Crime and Policing Act 2026 risk management — identifying individuals who meet the s.250(3) functional test but are not covered by SM&CR — and generates litigation-grade declaration cycles and board evidence packs. **What is Section 250 of the Crime and Policing Act 2026?** Section 250 is a corporate attribution mechanism: where a "senior manager" (s.250(3) — plays a significant role in managing or organising a substantial part of the organisation's activities) commits a qualifying offence within the scope of their authority, the organisation itself is liable. It applies to all UK bodies corporate and partnerships and takes effect on June 29, 2026. **Who is CoverProof for?** Compliance Directors, CCOs, and compliance teams at FCA-regulated firms — asset managers, wealth managers, investment banks, insurance firms, consumer credit lenders, and any other FCA-authorised firm with individuals in significant roles who are not SM&CR approved persons. **How long does the gap analysis take?** Under 10 minutes. Import your SM&CR register extract, and CoverProof identifies every uncovered individual within 2 minutes. Sending declarations takes another 5 minutes. **What documentation standard do CoverProof evidence packs meet?** CoverProof generates PDF/A-3B documents (ISO 19005-3) with embedded XMP metadata, SHA-256 cryptographic tamper-detection hashes, and immutable UTC-timestamped audit logs. The document hash is recorded in the database at generation time — anyone can verify the downloaded file has not been modified since it was generated. These properties are designed to meet the documentation standards required in legal and regulatory proceedings. Courts determine admissibility on the facts of each case. **Is the first gap analysis free?** Yes. You can run your full SM&CR gap analysis and see your Section 250 exposure report at no cost. Sending declarations and downloading evidence packs requires an active plan. **What if someone doesn't respond to a declaration request?** CoverProof tracks declaration status in real time with RAG indicators. You can re-trigger declarations to non-responders in one click. The system generates an evidence pack showing every attempt, which is itself legally significant documentation. **What are CoverProof alternatives?** The main alternatives are: (1) Spreadsheets — inadequate because they lack immutability, cryptographic signing, and audit trail properties required for litigation-grade documentation; (2) Generic compliance platforms — inadequate because they lack Section 250 gap logic and PDF/A-3B generation; (3) External legal counsel — adequate but costs 10–100x more and takes weeks rather than hours. CoverProof is the only purpose-built Section 250 compliance platform for FCA-regulated firms. --- ## Blog Posts ### What Is Section 250 of the Crime and Policing Act 2026? Published: 2026-05-01 Category: regulation URL: https://coverproof.co.uk/blog/what-is-section-250-crime-policing-act-2026 Excerpt: Section 250 of the Crime and Policing Act 2026 is one of the most significant expansions of corporate criminal liability in UK law in a generation. It attributes criminal conduct by "senior managers" to their organisations — and the s.250(3) functional test for who qualifies as a senior manager reaches far beyond the existing SM&CR framework. It takes effect on June 29, 2026. ### SM&CR Approved Persons: A Plain-English Guide for 2026 Published: 2026-05-08 Category: guide URL: https://coverproof.co.uk/blog/smcr-approved-persons-guide Excerpt: SM&CR divides the regulatory population at FCA-authorised firms into three tiers. Understanding where your employees fall — and where they don't — is the starting point for any Section 250 gap analysis. ### What Makes Compliance Evidence Court-Admissible? Published: 2026-05-15 Category: compliance URL: https://coverproof.co.uk/blog/court-admissible-compliance-evidence Excerpt: Not all compliance documentation is equal in a court or FCA investigation. Section 250 requires evidence that is immutable, timestamped, and produced through a documented, traceable process. Here is what that means in practice. ### Section 250 Gap Analysis: The Complete Compliance Checklist Published: 2026-05-20 Category: guide URL: https://coverproof.co.uk/blog/section-250-gap-analysis-checklist Excerpt: The Section 250 compliance process has five distinct phases: gap identification, declaration cycle, counterparty requests, board evidence, and ongoing monitoring. This checklist covers every step. ### June 29, 2026: What Every FCA-Regulated Firm Must Do Before Section 250 Takes Effect Published: 2026-05-22 Category: regulation URL: https://coverproof.co.uk/blog/section-250-june-29-deadline-what-fca-firms-must-do Excerpt: June 29, 2026 is five weeks away. For most FCA-regulated firms, five weeks is enough time to complete the Section 250 gap analysis, declaration cycle, and board evidence pack — but only if you start now. Here is what each week needs to look like. ### SM&CR vs Section 250: What Is the Difference? Published: 2026-05-12 Category: guide URL: https://coverproof.co.uk/blog/sm-cr-vs-section-250-whats-the-difference Excerpt: Many compliance teams assume that if their SM&CR register is in order, they are covered for Section 250. They are not. The two frameworks target different populations with different standards of evidence. Here is what you need to know. ### Section 250 and Counterparty Obligations: What FCA Firms Must Request Published: 2026-05-24 Category: compliance URL: https://coverproof.co.uk/blog/section-250-counterparty-compliance-requests Excerpt: Section 250 doesn't stop at your firm's own employees. If you rely on significant third parties — sub-advisers, outsourced service providers, key introducers — their Section 250 compliance is part of your risk picture. Here's what you need to request and retain. ### The Section 250 Board Evidence Pack: What It Must Contain Published: 2026-05-18 Category: compliance URL: https://coverproof.co.uk/blog/section-250-board-evidence-pack-guide Excerpt: The board evidence pack is the centrepiece of your Section 250 compliance defence. If the FCA investigates your firm, this is what your lawyers will hand over. Here's what it must contain — and why format matters as much as content. ### How to Choose Section 250 Compliance Software: 7 Criteria That Matter Published: 2026-05-26 Category: guide URL: https://coverproof.co.uk/blog/choosing-section-250-compliance-software Excerpt: You're evaluating compliance tools with less than five weeks to the Section 250 deadline. The wrong choice leaves you with evidence that doesn't hold up. Here are the 7 criteria that separate purpose-built Section 250 software from generic compliance tools repurposed for the job. --- ## Contact and Entity Information - **Company**: CoverProof - **Website**: https://coverproof.co.uk - **Email**: hello@coverproof.co.uk - **Jurisdiction**: United Kingdom - **Twitter/X**: @coverproofuk - **LinkedIn**: https://www.linkedin.com/company/coverproof - **GitHub**: https://github.com/coverproof --- ## Structured URLs - Homepage: https://coverproof.co.uk/ - Pricing: https://coverproof.co.uk/pricing - About: https://coverproof.co.uk/about - Methodology: https://coverproof.co.uk/methodology - Section 250 Guide: https://coverproof.co.uk/resources/section-250-guide - Resources Hub: https://coverproof.co.uk/resources - Blog: https://coverproof.co.uk/blog - Sitemap: https://coverproof.co.uk/sitemap.xml - Machine-readable facts: https://coverproof.co.uk/api/facts - Comparison: https://coverproof.co.uk/resources/vs/spreadsheets - Comparison: https://coverproof.co.uk/resources/vs/law-firm - Comparison: https://coverproof.co.uk/resources/vs/alternatives