Compare options
Four routes let a firm trade under FCA rules, and they differ by more than price. This page sets out what each actually costs, who each suits, and — more usefully — when each is the wrong answer.
Each guide sets out the criteria side by side, with a recommendation and the circumstances that reverse it. Most general first.
DIY vs Consultant: FCA Authorisation Application
A practical comparison of applying for FCA authorisation yourself versus engaging a specialist consultant. Covers cost, timeline, success rates, and the hidden complexities that catch most applicants off guard.
7 min read
Appointed Representative vs Direct FCA Authorisation
A detailed comparison of entering the UK regulated market as an Appointed Representative under a principal firm versus obtaining direct FCA authorisation. Covers speed, cost, control, flexibility, and long-term strategic implications.
7 min read
Generic Legal Advice vs Specialist FCA Consultant: Regulatory Support Options
A comparison of engaging a general commercial law firm versus a specialist FCA regulatory consultant for authorisation, ongoing compliance, variations of permission, and enforcement matters. Covers cost, depth of FCA-specific knowledge, practical experience, and implementation support.
7 min read
Spreadsheet Tracking vs Structured Platform: Consumer Duty Monitoring
A comparison of using spreadsheets and manual processes versus a purpose-built compliance platform for Consumer Duty outcome monitoring. Covers audit trail quality, MI production, evidence for FCA supervision, scalability, and the practical realities of annual board reporting.
8 min read
Basic Logging vs Root Cause Analysis: Complaints Handling Approaches
A practical comparison of simple complaints recording against implementing a full root cause analysis programme. Under Consumer Duty, the FCA expects firms to go beyond logging individual complaints and understand the systemic issues driving poor customer outcomes.
7 min read
FCA Credit Broking Authorisation Routes
Compare DIY, MEMA's £6,850 fixed-fee project and full consultancy for FCA credit-broking authorisation: FCA fees, timelines and risks, verified for 2026.
6 min read
The four routes, and what separates them
Almost every firm arriving at this decision is really choosing between four things: apply to the FCA directly, operate under somebody else's permission as an appointed representative, hire compliance people, or buy compliance expertise by the engagement. The first two decide whether you can trade at all. The second two decide how you stay compliant once you can.
They are routinely discussed as if they were a single spectrum from cheap to expensive. They are not. An appointed representative arrangement is not a discounted authorisation — it is a different commercial relationship in which another firm carries regulatory responsibility for what you do, and prices that risk accordingly.
| Route | Up-front cost to the FCA | Who carries the risk | Typically right when |
|---|---|---|---|
| Application fee by pricing category, plus an annual periodic fee | You do | The regulated activity is the business, not a feature of it | |
| No FCA application fee; the principal charges instead | Your principal does | Testing a market, or the activity is ancillary to the main business | |
| Salary, not a fee | You do | Volume and complexity justify a permanent role | |
| Engagement or retainer | You do — it cannot be delegated away | Specialist need, or a workload that is uneven across the year |
Direct authorisation
If the permission is what you sell, this is usually worth the cost and the wait. The alternative makes your ability to trade depend on another firm's continued appetite.
The application fee is the smallest number in the exercise. The real cost is preparing a regulatory business plan and financial projections that survive scrutiny, evidencing the Threshold Conditions, and building the compliance framework you have just told the FCA you will operate. The section below sets out the fees in full.
Appointed representative
Not a discounted authorisation. It is a different commercial relationship in which another firm carries regulatory responsibility for what you do, and prices that risk accordingly.
Arrangements commonly run on a revenue share or oversight fee. That avoids the application fee, but it is a recurring transfer rather than a one-off, and for a firm with meaningful revenue it can overtake the cost of getting authorised within a couple of years. Model it over three years, not one.
In-house compliance
Suits continuous work — monitoring, reporting and financial crime oversight run all year and benefit from someone who knows the firm.
It is expensive idle capacity for the other kind of work. Authorisation, a skilled person review under section 166, a variation of permission and a Consumer Duty implementation are projects with a start and an end.
Outsourced compliance
Worth stating plainly because it is often misunderstood: outsourcing the work does not outsource the responsibility. The senior managers accountable under SM&CR remain accountable whoever does it. What outsourcing buys is capability and capacity, not a transfer of liability.
It fits work that is uneven across the year, and specialist need — building the evidence a supervisor will accept is a practitioner question, and a different discipline from legal opinion.
One point is worth stating plainly because it is often misunderstood: outsourcing compliance work does not outsource regulatory responsibility. The senior managers accountable under SM&CR remain accountable whoever does the work. What outsourcing buys is capability and capacity, not a transfer of liability.
Four questions that decide it
Is the regulated activity the business, or attached to it?
What does the principal relationship really cost?
Is your compliance workload steady or spiky?
Are you buying regulatory judgement or legal advice?
Where this points
0 of 4Trading route
Answer 01 and 02.
Compliance resourcing
Answer 03.
A starting point, not advice. Which route is right turns on facts this page cannot see — the perimeter your activities fall inside above all.
Why these four questions
1. The activity
If the permission is what you sell, direct authorisation is usually worth the cost and the wait, because being an AR means your ability to trade depends on a principal's continued appetite. If the activity supports a wider business, the AR route often makes more sense.
2. The revenue
AR arrangements commonly run on a revenue share or oversight fee. It avoids the application fee, but it is a recurring transfer rather than a one-off, and for a firm with meaningful revenue it can overtake the cost of getting authorised within a couple of years. Model it over three years, not one.
3. The workload
Authorisation, a skilled person review under section 166, a variation of permission and a Consumer Duty implementation are projects with a start and an end. Monitoring, reporting and financial crime oversight are continuous. A permanent hire suits the second and is expensive idle capacity for the first.
4. What you need
These are different products and are often confused. A law firm will tell you what the rules require. What an application, a s166 response or a VREQ needs is someone who can build the evidence a supervisor will accept — which is a practitioner question, and a different discipline from legal opinion.
What direct authorisation actually costs
The FCA application fee is set by which of ten pricing categories your permissions fall into, ranging from £280 to £225,170. Most firms sit between £560 and £5,640: a limited permission consumer credit firm pays £560, while most financial advisers, mortgage brokers and general insurance intermediaries fall into Category 4, currently £2,820. Dual-regulated banks and insurers pay £28,150.
The application fee is the smallest number in the exercise. Once authorised, firms in the 'A' fee-blocks pay a minimum annual periodic fee of £2,200, more where reported income takes them above the minimum, plus FOS and FSCS levies where applicable. Beyond the regulator, the real cost is preparing a regulatory business plan and financial projections that survive scrutiny, evidencing the Threshold Conditions, and building the compliance framework you have just told the FCA you will operate.
A variation of permission is priced differently again, and not as a flat fee: adding an activity group you do not already hold costs 50% of the highest category relevant to the application, while a variation staying inside a fee-block you already hold costs a Category 1 or Category 2 fee. Reducing scope alone attracts no fee.
Source: FCA, Pricing categories for application fees and FEES 3 Annex 16R. Figures as at August 2026; the FCA revises them annually, so confirm before you budget.
Where MEMA fits
We are the fourth route: outsourced specialist support, bought by the engagement or on a retainer. That suits a firm with a project (an authorisation, a variation, a s166 response, a Consumer Duty build) or one whose ongoing workload does not yet justify a permanent hire.
It is the wrong answer if the regulated activity is small and incidental to your business, in which case an appointed representative arrangement is usually cheaper and faster. We will say so.