Do I send a DBS certificate to the FCA with my application?

No. The certificate isn't submitted with the application. The firm obtains it as part of assessing its senior manager's fitness and keeps it on record, producing it if the FCA asks.

Which DBS check does an SMF29 appointment need?

Senior management functions at regulated firms fall within the exceptions to the usual rehabilitation rules, so a standard DBS check — showing spent and unspent convictions and cautions — can be obtained and is the appropriate level for the fitness assessment.

How do I get a standard DBS check for an FCA role?

Through a DBS-registered umbrella body, applied for online with identity verification. The certificate is issued to the individual, typically for a modest fee, and the firm keeps it with its fitness records.

Will something on my DBS certificate stop authorisation?

Not automatically. It becomes part of the fit and proper assessment, weighed for what it was, when it happened and what's happened since — with dishonesty offences weighing heaviest. Consistency between the certificate and your application answers is essential.

Does the FCA do its own criminal records checks?

The FCA checks applications against its own intelligence and public records, and expects firms to have carried out criminal records checks on senior managers. Treat every question on the form as one the FCA can verify.

Do You Need a DBS Check for FCA Authorisation?

Here's the short answer, because it surprises people in both directions: no, you don't submit a DBS certificate with your FCA application — and yes, your firm is still expected to have carried one out on the person taking the senior management role. Here's how the two halves fit together.

Every limited permission consumer credit firm appoints a senior manager under the SMF29 function, and when a firm appoints someone to a senior management function it is expected to check that the person is fit and proper — including their criminal-record position. The check is the firm's job, done as part of assessing its own candidate. It is not an upload field on the application.

Which check — basic or standard?

A basic DBS check shows unspent convictions only, and anyone can request one about themselves. Senior management functions at FCA-regulated firms, however, are among the roles covered by the exceptions to the usual rehabilitation rules, which means a standard DBS check — showing spent and unspent convictions and cautions — can lawfully be obtained for the appointment. For an SMF29 appointment, the standard check is the one that matches what the fitness assessment is actually about.

How you actually get one

Standard checks are requested through a DBS-registered body — in practice, an online umbrella body that processes the application for a small fee. The individual completes an identity-verified application, and the certificate is issued to them. For a small firm authorising for the first time, the practical sequence is simple: the SMF29 candidate applies online, the certificate arrives, and the firm keeps it on record as part of its fitness assessment.

What to do with the certificate

File it. The certificate is evidence that the firm did its assessment — it sits in your records alongside the rest of your fit-and-proper documentation, and you produce it if the FCA ever asks. Nothing is posted to the FCA with the application. What the application does contain is a set of direct questions about convictions and history for the people behind the firm, and the FCA runs its own checks against those answers — which is exactly why the honest-disclosure rules in our fit and proper guide matter more than any certificate.

What if the check shows something?

A conviction on a DBS certificate is not an automatic bar, any more than a CCJ is. It becomes part of the fitness assessment: what it was, when, and what's happened since — with offences involving dishonesty weighing far more heavily than anything else. The rule that never bends is consistency: the answers on the application form, the firm's own assessment and the certificate in the file must all tell the same story.

Where this fits in the application

The DBS check is one small, cheap step in the wider picture the FCA assesses — the regulatory business plan, the compliance framework, the nominated SMF29 holder and the honesty of the disclosures. Our clients handle the DBS step themselves online in a few minutes; the pack we prepare does the rest. The full picture of what an application involves is in our step-by-step guide, and the costs in the cost guide.

This article is general information to help you understand the process, and is not legal or regulatory advice. CreditLicence is a document preparation service and is not affiliated with, endorsed by, or acting on behalf of the Financial Conduct Authority. FCA rules can change; always check the FCA's website for the current position.

Do you need a DBS check for FCA authorisation?