Section 250 Compliance for Asset Managers | CoverProof

TL;DR

Asset Managers face Section 250 obligations under the Crime and Policing Act 2026. 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 makes this an attribution-risk population for the organisation. Without a documented gap analysis and declaration cycle, the firm has a weaker governance record if a senior manager later commits an offence within actual or apparent authority. Typical Section 250 gap: Uncovered individuals in a mid-size asset manager. Key roles in scope: Portfolio managers (all strategies), Risk managers, Fund directors. Deadline: June 29, 2026. CoverProof automates the SM&CR gap analysis, declarations, and PDF/A-3B board evidence pack generation for asset management firms.

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Uncovered individuals in a mid-size asset manager

The typical Section 250 gap for a asset management firm — roles with significant financial authority that may sit outside SM&CR approval and need governance declarations now the law is in force.

Why asset management firms are particularly exposed

Portfolio managers not on the SM&CR register

Senior portfolio managers who do not hold a Controlled Function or Senior Management Function are outside your current SM&CR perimeter but within Section 250's reach. Most asset managers have between 5 and 30 such individuals.

Fund directors at offshore entities

Directors of Cayman or Luxembourg fund vehicles who also have a material UK role are a grey area under Section 250. If their UK responsibilities constitute a "significant role" in a financial firm, a gap analysis must address them.

Third-party sub-advisers

If you delegate portfolio management to a sub-adviser, you need to confirm their Section 250 coverage — and document that confirmation. A counterparty compliance request cycle creates the audit trail.

Roles typically in scope for asset management firms

⚑Portfolio managers (all strategies)
⚑Risk managers
⚑Fund directors
⚑Compliance officers not holding CF10
⚑Sub-adviser principals

Common questions from asset management compliance teams

Do sub-advisers need their own Section 250 declarations?

If the sub-adviser is itself an FCA-regulated firm, it has its own Section 250 obligations. As the appointing manager, you need to request confirmation of their gap analysis completion and retain that evidence — CoverProof's counterparty compliance request feature handles this.

What counts as a "significant role" under Section 250 for an asset manager?

The s.250(3) test asks whether the individual plays a significant role in the making of decisions about, or the managing or organising of, the whole or a substantial part of the organisation's activities — not just financial activities. A senior portfolio manager with discretionary authority over client assets and who shapes how a substantial part of the firm operates almost certainly qualifies.

We already have an SM&CR register. Does that mean we are covered?

No. SM&CR approved persons are a subset of the population Section 250 captures. The whole point of the legislation is to reach individuals who are significant but not SM&CR-approved. Your SM&CR register is the starting point, not the endpoint.

Run your gap analysis. Know your attribution risk now.

Import your SM&CR register and CoverProof identifies every individual in your firm who falls within Section 250's scope but outside your current approved-person perimeter. Your first gap analysis is free.

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