Exceptions to the fit and proper requirements

The application of the fit and proper requirements to sole traders is slightly different in some areas:

  • Sole traders are not required to seek regulatory references or criminal records checks for themselves, even where they also hold a Senior Manager Function (SMF).
  • Sole traders with employees should consider whether any of these individuals meet the definition of a Senior Manager or perform one of the Certification Functions.
    If so, the fit and proper requirements apply.
  • For employees of Sole Traders, if an employee is a senior manager or performs a Certification Function they are subject to criminal records checks.

Unfortunately Vero do not currently offer background screening packages for sole traders. You may wish to contact Robert Quinn Consulting for further advice and guidance on how to ensure compliance with Financial Conduct Authority requirements. If you need a DBS criminal record check, please go to to find a suitable umbrella body.