Final guidance and regulations for the Individual Accountability Framework

1. Significant reduction in the due diligence requirements and more time to complete 
   Enhanced annual due diligence is no longer required for CF3-CF11, which removes a significant additional administrative burden on firms. Enhanced due diligence is still required for pre-approved controlled functions (PCFs) and controlled functions (CF) 1 and 2. Self-certification is required for all other roles.
   
   Completion of the certification process for all CFs will relate to the 2024 calendar year and will be required in 2025.
   
   
2. Deferral of NEDs
   The CBI has deferred application of the Senior Executive Accountability Regime (SEAR) for non-executive directors (NEDs), including independent non-executive directors (INEDs) to 1 July 2025.
   
   
3. Reduction of prescribed responsibilities
   There has been a slight reduction in the number of prescribed responsibilities as a result of merging three responsibilities into one. This relates to diversity and inclusion and culture. (PR29, PR4 and PR5).
   
   Two responsibilities were also removed:
   • PR8: consideration of key business initiatives and strategic decisions to avoid harm to customers; and
   • PR26: developing a framework for monitoring the implementation of conduct requirements.
      
4. Limited ability to “job share” 
   Job sharing is allowed, but only for the following four roles:
   
   For insurance firms:
   • PCF-18 Head of Underwriting
   • PCF-19 Head of Investment
      
5. For investment firms:
   • PCF-29 Head of Trading
   • PCF-30 Chief Investment Officer
     
     This is not to be confused with other PCF roles, of which there may be more than one (PCF1, PCF 2A, PCF 2B, PCF 16, PCF 28, PCF 41 and PCF 50).
      
6. Disciplinary actions
   The final guidance was updated to remove a firm’s obligation to report formal disciplinary action. However, existing obligations still apply and all breaches remain reportable by the firm.

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