Senior Manager Authority Pack™ for UK financial services.
Every AI-assisted material decision — mapped to a named Senior Manager, bound to the SoR clause it discharges, and signed into a reasonable-steps Evidence Pack™ at the moment it happens. Interview transcripts and meeting notes are weak evidence in an FCA enforcement. KYE Protocol™ produces materially better evidence — the Senior Manager Authority Pack™ is the productisation that lands the better evidence inside UK Tier-1 banks.
UK SM&CR + the FCA Jan 2026 AI supervisory approach — named personal exposure meets material-AI-decision triggers.
The UK Senior Managers & Certification Regime makes named Senior Manager Functions personally accountable for the way their area is run. The FCA Jan 2026 AI supervisory approach extends “reasonable steps” coverage to AI-assisted decisions — customer outcome, vulnerable-customer treatment, pricing, complaints handling, suitability, product governance. Two facts converge:
- Personal regulatory exposure is named. SMF1 / SMF3 / SMF18 / SMF24 carry personal exposure, not the firm. The SoR is the regulator-of-record document against which conduct is tested.
- The current evidence base is weak. Interview transcripts plus meeting notes are the dominant evidence today. They are reconstructive, contestable, and unsigned. They do not derive from public keys alone.
- KYE Protocol™ produces materially better evidence. Authority Finality™ on every AI-assisted decision, bound to the named SMF, the SoR clause, and the delegation chain. The reasonable-steps Evidence Pack™ is signed, replay-derivable from published JWKS, and produced at the moment the action commits — not reconstructed afterwards.
- The buyer is named and budget-holding. SMF24 (Chief Operations function) at every UK Tier-1 bank by mid-2026. They carry the exposure; they hold the budget; the FCA Jan 2026 clock is running.
Better evidence than interview transcripts — signed at the moment, derivable from public keys alone.
- Signed at the moment of the decision. No reconstruction, no contested timeline. The Evidence Pack™ carries the SMF identity, the SoR clause, the delegation chain, and the Authority Finality™ outcome — sealed at the moment the AI action commits.
- Replay-derivable from published JWKS. An FCA enforcement decision-maker can verify the evidence chain offline, against published keys alone. No vendor cooperation required. No private envelope. No bilateral trust.
- Materially-AI-decision-aware. Six FCA Jan 2026 triggers covered as canonical rules. Customer outcome, vulnerable-customer treatment, pricing, complaints handling, suitability, product governance — each routed through the Authority Register before the action commits.
- Quarterly attestation cadence. Every quarter, each designated SMF co-signs a kye.compliance.attestation.v1 envelope covering their AI-assisted decision register. The FCA-style spot-check is always less than 90 days away from clean.
- Conduct-Rule-breach native. CR1-CR5 and SC1-SC4 breaches meeting the FCA SUP 15.3 materiality threshold emit a conduct-incident Evidence Pack™ routed dual-channel to SMF and compliance per banking-grade.
An 8-step pipeline — from AI decision to board / compliance view.
Every material AI decision flows through the same eight steps. The pipeline is bound to canonical KYE Protocol™ envelopes — no parallel surfaces, no bespoke shapes per firm.
- 1 — AI decision proposed. The AI agent or operational team proposes an action that classifies as a material AI decision (customer outcome, vulnerability flag, pricing, complaints, suitability, product governance).
- 2 — KYE™ authority check. The Action Admissibility™ Gate verifies the named SMF mapping, the SoR coverage, and the delegation chain. No mapping = no action.
- 3 — Evidence Pack™ assembled. The runtime emits kye.purpose.request.v1 + kye.purpose.admissibility.v1 + kye.evidence.decision_map.v1 + kye.evidence.pack.v1 in lockstep.
- 4 — Authority Finality™ outcome. The action either commits or is refused. The outcome is bound to the SMF for SC3 reasonable-steps evidence.
- 5 — SMF mapping recorded. The named Senior Manager (SMF1/3/18/24 or registered SMF) is recorded on the Evidence Pack™ envelope, signed.
- 6 — SoR clause bound. The Statement of Responsibilities clause discharged by the action is bound to the envelope. The clause is queryable per SMF, per quarter, per material-decision class.
- 7 — Reasonable-steps evidence emitted. The signed reasonable-steps Evidence Pack™ is sealed and made replay-derivable. Available to the responsible SMF, compliance, audit, and the FCA / PRA on enforcement demand.
- 8 — Board / compliance view. The AI-assisted decision register surfaces in the board pack and the compliance dashboard. The SMF reviews quarterly and co-signs the attestation envelope.
Bound to the canonical UK SM&CR regulatory perimeter.
The Pack binds the canonical KYE™ artefact set to the UK financial-services regulatory perimeter. Every claim resolves to a control row on the bound framework.
| Framework | Control area | Pack coverage |
|---|---|---|
| UK SM&CR | SUP 10C SMF functions (SMF1 / SMF3 / SMF18 / SMF24) | full |
| UK SM&CR | SYSC 25 Statement of Responsibilities (SoR) | full |
| UK SM&CR | COCON 2.2 Senior Conduct Rules SC1–SC4 | partial |
| UK FCA AI Jan 2026 supervisory approach | Material AI decision triggers (6 categories) | full |
| UK FCA Conduct | PRIN 2A Consumer Duty | partial |
| UK PRA SS28/15 | Senior Managers Regime governance expectations | partial |
Full coverage means every requirement in the control area is bound to a canonical KYE™ rule, dictionary term, or evidence-pack contract. Partial coverage means the bound surface satisfies the control area when paired with the firm’s own attestation envelope.
Qualified UK financial-services partners — apply through the Foundry.
The Senior Manager Authority Pack™ is the first canonical reference template under constitution §54 §13. Productisation is via the KYE Sector Pack Foundry™ Build tier; commercial distribution is value-based, qualification-gated, and disclosed under NDA to qualified applicants.