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
  1. 01Map the permission firstThe business model and permissions come first. Every other document is built around them.
  2. 02Final and tailoredThe FCA wants signed-off documents that fit your firm, not templates it has to finish with you.
  3. 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.

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.

1 min read · 1 sections

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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.

The core documents and what each must establish
Document or evidenceWhat it must establish
Application formAnswers 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 analysisWhy 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 planTailored to your business: governance, business model, customer journey, compliance, complaints, capital and policies.
Financial forecasts and notesIncome statement, balance sheet and cash flow, with the assumptions behind them.
Controllers and individualsThe right forms for people performing key roles and for anyone with a qualifying holding. A clear ownership structure chart helps.
Policies and proceduresHow the rules will actually be met by this firm, with named owners.
6 months
the longest a controller's criminal background check may be old at application
A standard DBS check, or a basic check for sole directors (England and Wales; equivalent checks elsewhere).
Up next · Chapter 2Document the business model in operational detail

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.

1 min read · 2 sections

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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

What to document about how the firm really works

  • Customer journey

    From finding the customer to after-sales care, and any customers acquired from another firm.

  • Fees and revenue

    What is charged, how it is explained to the customer, and whether any client money is held.

  • Funds flow

    Diagrams showing how money moves, where relevant.

  • Outsourcing

    What is outsourced, to whom, and how the firm oversees it.

  • Systems and IT

    Planned systems, whether bought or built, with realistic timelines.

  • Customers in vulnerable circumstances

    How the firm identifies them and what support it offers.

  • Marketing

    Marketing plans and any financial promotions the firm is using or planning.

  • Complaints

    How complaints are monitored and what happens if the customer is unhappy.

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.

Up next · Chapter 3Financial forecasts and prudential evidence

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.

2 min read · 1 sections

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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
Up next · Chapter 4Which documents depend on the activity?

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.

2 min read · 2 sections

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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.

Six FCA sector pages to find and read

  • Payment and e-money institutions

    Apply to become an e-money or payment institution, and the payment institution applicants page.

  • Consumer credit brokers

    Apply to become a consumer credit broker.

  • Mortgage brokers

    Apply to become a mortgage broker.

  • General insurance intermediaries

    Apply to become a general insurance intermediary.

  • Consumer investments

    Apply to become a consumer investments firm.

  • Claims management

    Apply to become a claims management company.

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

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.

Up next · Chapter 5Final review: does the pack tell one story?

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.

1 min read · 2 sections

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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.

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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
Up next · Chapter 6How to assemble the submission efficiently

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.

1 min read · 2 sections

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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.

An illustrative eight-week assembly plan
W1W2W3W4W5W6W7W8
Permissions and perimeter analysisBoardWeek 1–2
W1–2
Business plan draftCEOWeek 2–4
W2–4
Forecasts and capital evidenceFinanceWeek 3–5
W3–5
Policies tailored to the modelComplianceWeek 3–6
W3–6
Individuals and controllers formsCompany secretaryWeek 4–6
W4–6
Side-by-side reviewIndependent reviewerWeek 7
W7
Submit on ConnectBoardWeek 8

Illustrative example Not FCA figures. Use your own.

Questions people ask
QuestionShort 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.

You have reached the endSee the sources

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.

  1. FCA: How to apply for authorisation or registration
  2. FCA: Authorisation and registration applications, good practice and areas for improvement
  3. FCA: Preparing your firm's financial information
  4. FCA: Sample business plan
  5. FCA: Payment institution applicants
  6. FCA: Apply to become an e-money or payment institution
  7. FCA: Apply to become a consumer credit broker
  8. FCA: Apply to become a mortgage broker
  9. FCA: Apply to become a general insurance intermediary
  10. FCA: Apply to become a consumer investments firm
  11. 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.

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