MEMA Guides / FCA authorisation
FCA authorisation: what documents will you actually need?
A practical evidence checklist for founders: what should exist before you apply, which documents must agree with each other, and what changes with your permission type.
- 3 yearsof forecasts in Excel and, if you already trade, of accounts, is best practiceSource
- No draftsthe FCA expects final, signed-off documents and says it will not review draftsSource
The guide in 30 seconds
Practical guidance- 01Map the permission firstThe business model and permissions come first. Every other document is built around them.
- 02Final and tailoredThe FCA wants signed-off documents that fit your firm, not templates it has to finish with you.
- 03One storyThe plan, forecast and policies must name the same people, products and providers.
Explore the chapters
Read them in order, or jump to the one you need.
01The core pack almost every applicant must think aboutBegin with a master document register so nobody works to an obsolete version. These are the pieces the FCA names on its own pages.
02Document the business model in operational detailA case officer should be able to follow a customer from first contact to closure. Generic assurance gives them nothing to assess.
03Financial forecasts and prudential evidenceThe figures must reconcile with the business plan and with each other. Errors in the opening position are not editorial slips: they weaken the financial resources case.
04Which documents depend on the activity?Use the FCA page for your sector and the application form. Do not import another firm's list wholesale.
05Final review: does the pack tell one story?Ask someone who did not draft the documents to compare them side by side. Inconsistency is a common way for a good business to look unready.
06How to assemble the submission efficientlyThe aim is a reviewable application, not the highest number of attachments. Plan the assembly, then check before you pay an application fee the FCA does not refund if you withdraw or are refused.
Chapter 01 · Start here
The core pack almost every applicant must think about
Begin with a master document register so nobody works to an obsolete version. These are the pieces the FCA names on its own pages.

The FCA's how to apply page is the starting point. It says your application is submitted on Connect, and that the FCA will reject a submission without assessing it if you do not provide the minimum information it asks for. Your sector page tells you which forms and supporting material apply to you.
The FCA also tells applicants what it does not want. Documents should be final versions, thoroughly reviewed and appropriately signed off. It will not review drafts. Policies should not be generic templates: they need to be tailored to the business model.
| Document or evidence | What it must establish |
|---|---|
| Application form | Answers to every question. Where something does not apply, explain why in your supporting documents. The FCA asks payments applicants to do this, and it helps any application. |
| Permissions analysis | Why each permission applied for fits what the firm will do. The FCA has seen firms give legal advice or point to the Perimeter Guidance Manual. |
| Regulatory business plan | Tailored to your business: governance, business model, customer journey, compliance, complaints, capital and policies. |
| Financial forecasts and notes | Income statement, balance sheet and cash flow, with the assumptions behind them. |
| Controllers and individuals | The right forms for people performing key roles and for anyone with a qualifying holding. A clear ownership structure chart helps. |
| Policies and procedures | How the rules will actually be met by this firm, with named owners. |
Chapter 02 · Show how it works
Document the business model in operational detail
A case officer should be able to follow a customer from first contact to closure. Generic assurance gives them nothing to assess.

Saying that "robust controls are in place" is not evidence. Name the owner, how often the control runs, the record it leaves, where exceptions go and who they are reported to. The FCA's published good practice for applicants (September 2025) lists what it keeps seeing go wrong.
Generic and specific
What the FCA says goes wrong
- Policies not tailored, so the FCA cannot see how they would be implemented
- Policies that repeat the FCA's rules rather than document how the firm will comply
- Templated policies that do not align and do not make sense together
- Unclear information on planned IT systems and infrastructure
What it looks for
- Policies that show how the rules are met in this firm
- Each permission analysed against the firm's intended activities
- A step-by-step customer journey, from acquiring the customer to after-sales
- Off-the-shelf, modified or custom systems identified, with realistic timelines
The Consumer Duty should run through all of this. The FCA's sample business plan says the Duty should feature throughout the plan, and good practice is to weave it into policies, procedures and controls, rather than repeating the Duty in a separate document. A firm outside the Duty must say why, and show how it will meet Principles 6 and 7.
Chapter 03 · The numbers
Financial forecasts and prudential evidence
The figures must reconcile with the business plan and with each other. Errors in the opening position are not editorial slips: they weaken the financial resources case.

Every applicant must have financial forecasts in place before the FCA can assess the application. A firm that is already incorporated and trading must also provide historical accounts. All information must be in English, and customised to your business, your legal structure and your sector.
A forecast that shows a profit while the business plan promises to hire six people before launch is a problem. The payroll has to appear at the right point. The FCA names the errors it sees: balance sheets that do not balance, and opening and closing accounts that do not match across years.
Build the financial case in five steps
Stage 1 of 5
Opening position
Explain how the firm will hold enough capital to meet its capital resource requirement. The figure must agree with the business plan and the financial information you send.
- Set out the requirement that applies to your permissions
- If you are under a quantified prudential regime, show share capital and any capital-enhancing instruments
- Match every figure to the business plan
Stage 2 of 5
Linked forecast
Provide forward-looking projections covering the three statements. Three years of forecasts in Excel is best practice, and the FCA accepts monthly and yearly projections.
- Use the FCA's template for your sector where there is one
- Check the balance sheet balances
- Check closing and opening figures match across years
Stage 3 of 5
Assumptions
Share notes to the accounts and the key assumptions behind the forward-looking plan, so the case officer can follow your reasoning.
- State assumptions for volumes, fees and costs
- Cross-refer to your management information
Stage 4 of 5
Stress test
Payments and e-money firms are asked for balance sheet forecasts and two stress-tested scenarios where applicable. Other firms can add stress testing in their own format.
- Model delayed revenue and higher losses
- Show the effect of a supplier or partner failing
Stage 5 of 5
Funding proof
The FCA saw good practice where firms provided evidence of their funding arrangements, highlighted commitments and contingency plans, and used bank statements where funding was simple.
- Gather share subscriptions and commitments
- Include historical accounts if you already trade
Chapter 04 · Use your sector page
Which documents depend on the activity?
Use the FCA page for your sector and the application form. Do not import another firm's list wholesale.

The FCA publishes a separate page for each type of firm. Each lists the forms, the supporting material and the specific things it expects to see. They differ more than most founders expect. The views below pick out what each page says is particular to that sector.
What the FCA's sector pages add
The payment institution page lists the supporting material for each route.
- A programme of operations and business plan, with financial information
- Controls to meet money laundering obligations, and a security policy
- Safeguarding measures, incident reporting and sensitive payment data procedures
- For authorised firms: initial capital and ongoing capital calculation, and a wind-down plan
- Outsourcing arrangements and how agents will be used and checked
Both sector pages ask for a business plan, forecasts, policies and forms on Connect.
- Credit brokers: choose Limited or Full Permission when you start the application
- Mortgage brokers: explain how you source customers, including introducers and lead generators and your due diligence on them
- Mortgage brokers: include the actual Initial Disclosure Document you intend to use
- Both: show how you will deliver good outcomes for retail customers
The general insurance page asks for more than documents.
- A regulatory business plan that is tailored, not a generic marketing document
- Your principal place of business: serviced offices are generally considered inadequate
- A UK bank account and your Companies House registration details
- Client money accounts, if you propose to hold client money
- Evidence you have addressed the risks in the FCA's portfolio letters
Consumer investment firms and claims management companies have their own pages.
- Investments: explain how each permission matches your business and how you will hold client money or assets
- Investments: identify the prudential sourcebook that applies to you, such as MIFIDPRU
- Claims: set out the end-to-end lead and claims journey and the agreements behind referrals
- Claims: explain how you comply with direct marketing law and why your fees represent fair value
Many applicants must also register individuals in senior roles and controllers. Do not assume an outsourced compliance resource removes the need for accountable people in the firm. For consumer investment firms, the FCA says past industry experience alone will not satisfy it that someone is competent to be Head of Compliance or MLRO.
Chapter 05 · The side-by-side test
Final review: does the pack tell one story?
Ask someone who did not draft the documents to compare them side by side. Inconsistency is a common way for a good business to look unready.

The FCA's own words: the policies should be capable of being read together, so that the reader can join the dots and understand how the firm will apply them day to day. Here is a worked example of what happens when they do not.
The side-by-side review
Tick each item you can evidence. Your ticks stay in this browser only.
Facts that must agree everywhere
- The legal entity and its group structure
- The regulated activities and the permission wording
- Who holds customer money, and where
- Every named provider and the service it supplies
- Headcount, start dates and who does what
- The capital figure and where it comes from
Chapter 06 · A reviewable application
How to assemble the submission efficiently
The aim is a reviewable application, not the highest number of attachments. Plan the assembly, then check before you pay an application fee the FCA does not refund if you withdraw or are refused.

Keep one index showing document title, regulatory purpose, owner, current version, approval date, the application question it answers and its status. Read the guidance for your sector and the relevant Connect forms before you finalise. Where something genuinely does not apply, give a short explanation.
Illustrative example Not FCA figures. Use your own.
| Question | Short answer |
|---|---|
| Does every applicant need an MLRO? | The roles you must fill depend on your regime and activities. Use your sector page and the individuals forms. Do not lift another sector's role list into your application. |
| Can I submit template policies? | The FCA says policies should not be generic templates. Use templates only as a starting point and tailor every one. |
| Should I wait for every supplier to sign? | Identify the critical dependencies. The FCA expects the systems you will use to be ready for the applied-for activities. A material unresolved dependency may make the application premature. |
If a third-party contract is conditional on authorisation, say which parts are agreed, which are contingent, and how you will show the service is ready on the day you are authorised.
Where this comes from
Sources
Every number and rule in this guide comes from these pages. Check them before you rely on anything, as rules change.
- FCA: How to apply for authorisation or registration
- FCA: Authorisation and registration applications, good practice and areas for improvement
- FCA: Preparing your firm's financial information
- FCA: Sample business plan
- FCA: Payment institution applicants
- FCA: Apply to become an e-money or payment institution
- FCA: Apply to become a consumer credit broker
- FCA: Apply to become a mortgage broker
- FCA: Apply to become a general insurance intermediary
- FCA: Apply to become a consumer investments firm
- FCA: Apply to become a claims management company
This guide is general information, not legal or regulatory advice. Rules and FCA expectations change; check the sources and take advice on your firm's circumstances.
