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Authorisation45 min readLast updated January 2025

Complete FCA Authorisation Guide

Everything you need to achieve FCA authorisation, from initial scoping through to final approval. Written by ex-FCA regulators based on 500+ successful applications.

ME
MEMA Editorial Team
Ex-FCA Regulators
Expert Reviewed
50+ Pages

At a Glance

  • FCA authorisation typically takes 6-9 months from planning to approval
  • Application fees range from £1,500 to £25,000+ depending on complexity
  • You'll need 50-100 pages of supporting documentation
  • Initial capital requirements vary from £20,000 to £730,000
  • Key personnel must be fit and proper with relevant experience
  • MEMA achieves authorisation in 12 weeks average vs industry 20+ weeks

1. Understanding FCA Authorisation

What is FCA Authorisation?

FCA authorisation is the regulatory approval required to conduct regulated financial services activities in the UK. The Financial Conduct Authority (FCA) is the primary regulator for financial services firms, responsible for ensuring firms meet appropriate standards to protect consumers and maintain market integrity.

The authorisation process is designed to ensure that only firms meeting the FCA's regulatory standards can operate in the UK financial services market. This includes demonstrating adequate resources, competent management, robust systems and controls, and appropriate business models that deliver fair outcomes for consumers.

Do You Need FCA Authorisation?

Determining whether you need FCA authorisation depends on the activities your firm intends to conduct. The FCA regulates a wide range of financial services activities, known as "regulated activities" under the Financial Services and Markets Act 2000 (FSMA).

Key Regulated Activities

Accepting deposits
Taking money from the public with promise to repay
Dealing in investments
Buying, selling securities or derivatives
Arranging deals
Bringing together buyers and sellers of investments
Managing investments
Discretionary portfolio management
Investment advice
Recommending specific investment products
Consumer credit
Lending, credit broking, debt advice
Payment services
Money remittance, payment initiation
Insurance distribution
Advising on or arranging insurance

Perimeter Guidance Tool

Use our free Perimeter Assessment Tool to determine whether your business activities require FCA authorisation and which specific permissions you'll need.

Try Perimeter Assessment Tool

Timeline and Costs

Understanding the timeline and costs involved in FCA authorisation is crucial for business planning and resource allocation.

Typical Authorisation Timeline

1
Pre-application preparation8-12 weeks

Scoping business model, preparing documentation, establishing systems

2
Application submission1-2 weeks

Completing Connect forms, uploading documents, payment

3
FCA assessment12-16 weeks

FCA review, clarification questions, interviews

4
Conditional approval2-4 weeks

Meeting any conditions before final authorisation

Total timeline: 6-9 months from initial planning to full authorisation

With MEMA's expertise, we typically achieve authorisation in 12 weeks from submission, compared to the industry average of 20+ weeks.

Application Fees

FCA fees vary significantly depending on your permissions and sector:

Fee TypeAmount
Standard application£1,500
Complex applications (deposit-taking)£25,000+
Variation of Permission (VOP)£250 - £1,500
Annual fees£1,000 - £100,000+

FCA Fee Calculator

Calculate your exact FCA application and annual fees using our comprehensive FCA Fee Calculator.

Calculate Your FCA Fees

Additional Costs to Consider

Compliance consultancy£10,000 - £50,000
Legal fees£5,000 - £20,000
Systems and software£5,000 - £30,000
PI Insurance£3,000 - £15,000/yr
Ongoing compliance£30,000 - £80,000/yr

2. Pre-Application Preparation

Business Model Scoping

Before starting your FCA application, you must clearly define your business model and how it operates within the regulatory framework. This involves:

Defining your target market

Who are your clients? Retail, professional, or eligible counterparties?

Mapping your revenue model

How will you generate income? Fees, commissions, spreads, or other mechanisms?

Identifying distribution channels

Direct to consumer, B2B, introducers, or partnerships?

Determining operational scope

Geographic reach, product range, and service delivery model

Understanding client journey

How clients discover, onboard, transact, and are serviced

Permissions Mapping

Accurately identifying the regulated activities and permissions your firm needs is critical to a successful application. Getting this wrong leads to delays, additional costs, or operating illegally.

Key Steps in Permissions Mapping

  1. 1
    Identify all regulated activities

    Review every aspect of your business against the Regulated Activities Order (RAO)

  2. 2
    Determine permission scope

    Full permissions vs. limited permissions (e.g., advising vs. dealing)

  3. 3
    Specify investment types

    Which instruments will you handle? (equities, bonds, derivatives, CIS, etc.)

  4. 4
    Client categorisation

    Will you serve retail clients, professionals, or both?

  5. 5
    Consider future growth

    Plan for permissions you'll need in 12-24 months to avoid costly VOPs later

Common Mistake

Many firms apply for too narrow permissions, requiring expensive Variation of Permission applications within months of authorisation. Work with regulatory experts to future-proof your permissions scope.

Resource Requirements

The FCA requires firms to have adequate financial and non-financial resources to conduct their business and meet regulatory obligations. This is assessed through the Threshold Conditions.

1
Financial Resources

Initial capital requirement

Varies by permission, typically £20,000-£730,000

Ongoing capital requirements

Monthly or quarterly calculations based on base capital, expenditure-based, or activity-based requirements

Professional Indemnity Insurance

Minimum coverage levels specified per permission type

Working capital

Sufficient funds to cover 12 months of operating expenses

2
Key Personnel Requirements

You'll need to identify and appoint individuals to fulfill key regulatory roles:

SMF1Chief Executive

Overall responsibility for regulated activities

SMF3Executive Director(s)

Board-level responsibility for specific areas

SMF16Compliance Oversight

Compliance monitoring and regulatory reporting

SMF17MLRO

AML/CTF compliance and SAR reporting

Each individual must complete an Approved Persons/Senior Managers application demonstrating they are fit and proper through qualifications, experience, and regulatory history.

SMCR Navigator

Use our SMCR Navigator tool to understand which Senior Management Functions you need and the requirements for each role.

Explore SMCR Requirements

3. The Application Process

The FCA application is submitted through Connect, the FCA's online portal. The application consists of several components that must be completed accurately and comprehensively.

Connect Submission

You'll need to create a Connect account and navigate through several sections:

1
Firm Information

Legal entity details, corporate structure, ownership, and control

2
Permissions

Specific regulated activities and investment types you're applying for

3
Business Model

Detailed description of your business plan, revenue model, and target market

4
Senior Management

Details of all individuals performing Senior Management Functions

5
Financial Projections

Three-year forecasts including P&L, balance sheet, and cash flow

6
Supporting Documents

Upload of required policies, procedures, and governance documentation

Required Supporting Documents

A comprehensive FCA application typically requires 50-100 pages of supporting documentation including:

Business plan with market analysis
Financial projections (3 years)
Compliance manual
Risk assessment framework
AML policies and procedures
Complaints handling procedures
Client classification processes
Conflicts of interest policy
Outsourcing arrangements
Data protection policies
T&C framework
Client agreements
Financial promotions samples
MI reporting templates
Statements of Responsibilities
Organizational chart
Remuneration policies
PI Insurance certificate

Template Library

Access our comprehensive template library with ready-to-use compliance manuals, policies, and procedures tailored to your FCA permissions.

Browse Policy Templates

4. Key Requirements

Threshold Conditions

The FCA's Threshold Conditions are the minimum standards that firms must meet to become authorised and remain authorised. They form the core assessment criteria for any FCA application:

1
Location of offices

UK-based mind and management, appropriate office arrangements

2
Effective supervision

FCA must be able to effectively supervise your firm

3
Appropriate resources

Adequate financial and non-financial resources

4
Suitability

Fit and proper management, competent staff, appropriate systems

5
Business model

Viable business that won't cause consumer harm

Fit and Proper

All individuals holding Senior Management Functions or Controlled Functions must demonstrate they are "fit and proper" to perform their roles. The FCA assesses three key areas:

Honesty, integrity and reputation

Criminal records, regulatory sanctions, financial soundness

Competence and capability

Qualifications, experience, knowledge of the role

Financial soundness

Personal financial history, CCJs, bankruptcies

SYSC Requirements

The Senior Management Arrangements, Systems and Controls (SYSC) sourcebook sets out the FCA's requirements for governance, systems and controls. Key areas include:

General organisational requirements
Governance and management arrangements
Risk management policies and procedures
Internal controls and compliance oversight
Record keeping requirements
Conflicts of interest management

5. Regulatory Frameworks

SMCR Implementation

The Senior Managers and Certification Regime (SMCR) applies to all FCA-authorised firms and requires:

Identification of Senior Management Functions (SMFs)
Statements of Responsibilities for each SMF holder
Responsibilities Map showing how responsibilities are allocated
Certification of staff in certified roles annually
Conduct Rules training and attestation for all staff

Financial Crime

All FCA-authorised firms must have robust systems and controls to prevent financial crime:

Anti-Money Laundering (AML)

Customer due diligence, ongoing monitoring, suspicious activity reporting

Counter-Terrorist Financing (CTF)

Sanctions screening, PEP identification

Fraud prevention

Internal controls, transaction monitoring, staff vetting

Bribery and corruption

Policies, procedures, and staff training

Client Assets

If you hold client money or custody assets, additional CASS rules apply:

Segregation of client money from firm money
Daily reconciliations and record-keeping
Appropriate custodial arrangements
Client money protection insurance
Annual CMAR reporting to the FCA

6. Post-Submission

FCA Queries

During assessment, the FCA will likely raise queries about your application. Common areas include:

Clarification of business model and target market
Additional detail on financial projections and assumptions
Evidence of systems and controls implementation
Further information about key personnel
Requests for sample documentation

Interviews

The FCA may require interviews with your proposed Senior Managers. These typically cover:

Understanding of the firm's business model and risks
Knowledge of regulatory requirements
Experience and competence for the role
Understanding of specific responsibilities

Conditional Approval

The FCA may grant authorisation subject to conditions. Common conditions include:

Restrictions on business activity until specific milestones are met
Requirements to implement additional controls
Limits on client money holdings
Enhanced reporting requirements

7. Common Pitfalls

Why Applications Fail

Inadequate financial resources

Insufficient capital or unrealistic financial projections

Poor governance arrangements

Unclear responsibilities, inadequate oversight structures

Weak systems and controls

Policies that don't reflect actual business operations

Fit and proper concerns

Issues with key personnel's history or competence

Non-viable business model

Unrealistic assumptions or unsustainable economics

Red Flags

The FCA looks closely at applications that show:

History of regulatory issues at other firms
Complex corporate structures with unclear ownership
Overreliance on outsourcing for core functions
Unclear or changing business model during assessment
Poor quality documentation or inconsistent information

How to Avoid Delays

Ensure all documentation is complete before submission
Respond promptly and thoroughly to FCA queries
Have key personnel available for interviews at short notice
Work with experienced regulatory consultants
Maintain consistent messaging throughout the process

8. Sector-Specific Guidance

Payments

Payment services firms face additional requirements under the Payment Services Regulations 2017:

Safeguarding requirements for customer funds
Strong customer authentication (SCA) implementation
Open banking compliance
Specific capital requirements based on payment volume

Investments

Investment firms must comply with MiFID requirements:

Best execution policies and monitoring
Suitability and appropriateness assessments
Inducements and conflicts management
Product governance requirements
Transaction reporting obligations

Consumer Credit

Consumer credit firms have specific obligations under CONC:

Creditworthiness and affordability assessments
Responsible lending practices
Arrears and forbearance procedures
Financial promotions compliance
Section 75 and chargeback handling

Key Takeaways

FCA authorisation is essential for conducting regulated financial services in the UK
Plan for 6-9 months from initial preparation to final approval
Invest time in accurate permissions mapping to avoid costly variations later
Ensure key personnel are fit and proper with relevant experience
Build robust systems and controls that reflect actual business operations
Respond promptly and thoroughly to FCA queries during assessment
Expert Support Available

Need Expert Guidance?

While this guide provides comprehensive information, FCA authorisation is complex. Our regulatory experts can help you navigate the process with confidence.

500+
Firms Authorised
Since 2015
98%
Success Rate
First-time approvals
12 wks
Average Timeline
vs. industry 20+ weeks