5 | News and updates
IFR publishes CP1/25 Owners, Directors & Senior Executives (ODSE) Response Document
On 5 December 2025 the IFR published its response to the feedback received during its consultation on how the IFR proposes to establish and oversee the Owners, Directors & Senior Executives (ODSE) regime as set out in Part 4 of the FGA.
The final ODSE rules, guidance, and application forms were also published on 5 December 2025, forming the basis of the ODSE regime. The IFR was able to consider the suitability of incumbent owners from 12 December 2025 and will receive powers to test suitability of new applicants from May 2026.
In response the IFR made:
- Changes to the draft rules, amending the definition of the Chief Operations Officer function (SMF4) to refine the scope following industry feedback. The IFR also amended the title of the proposed Significant Influence function (SMF6) to Other Key Decision Maker function (SMF6).
- Amendments to the draft guidance including:
o further guidance on what is meant by the IFR being “in possession of information that gives us grounds for concern” in relation to incumbents; and
o the inclusion of examples of roles that may be captured under the Other Key Decision Maker function (SMF6) (previously the Significant Influence function).
- Changes to proposed application forms. This includes enhancing the information requested in order to identify the subject of an application, such as their personal details (home address, contact number, email address etc), and a requirement to provide verified ID. The IFR also confirmed it will be possible to submit applications digitally.
The IFR is considering whether it would be appropriate to develop additional rules to address specific operational uncertainties (e.g. covering temporary absences of Senior Managers). It is likely that such proposals will be consulted on separately via a future consultation.
