MEMA Guides / FCA authorisation
What does "ready, willing and organised" mean to the FCA?
Turn a familiar FCA phrase into an evidence test for your board, management, product, systems and submission pack, before you pay the fee.
- Day oneyou must have the arrangements and documents in place to comply from the day you are authorisedSource
- Why nowthe FCA considers why you are applying now, and whether you could carry out the activity if authorised todaySource
The guide in 30 seconds
Practical guidance- 01ReadyYou have done the preparation and your documents are final, not drafts for the FCA to improve.
- 02WillingYou are open and honest, and your own people respond quickly to questions.
- 03OrganisedIf authorised today, you could carry on the activity, not still have something to fix.
Explore the chapters
Read them in order, or jump to the one you need.
01Ready: the firm has done the preparationThe application is not an invitation for the FCA to design your business. The FCA expects you to have done the work first.
02Willing: management shows regulatory responsibilityA consultant can support an application. The firm's own people must own it, and answer for it.
03Organised: the operating model works from authorisationDescribe controls as actions with owners and evidence. Organised does not mean trading at full scale before approval.
04The three-document consistency testIf the business plan, forecast and policies disagree, the firm is not ready. The FCA wants to see the dots joined.
05Worked example: a fintech with a finished appTechnology readiness is not the same as regulatory readiness. A built product does not make an organised firm.
06Pre-submission readiness scorecardA useful board challenge before you pay an application fee the FCA does not refund if you withdraw or are refused.
Chapter 01 · Part one
Ready: the firm has done the preparation
The application is not an invitation for the FCA to design your business. The FCA expects you to have done the work first.
The FCA's how to apply page says it expects firms to be ready, willing and organised to comply with its current rules and guidance on an ongoing basis, and with any rules it introduces in future. In your application you need to show that your firm can do this and that you have planned ahead.
We expect all documents to be final versions that have been reviewed thoroughly and appropriately signed off before you submit them. We won't review draft documents.
Being ready also means being able to explain your regulatory obligations. The FCA suggests you consider seeking legal or compliance advice, and its published good practice shows what readiness looks like: a tailored regulatory business plan, forecasts that reconcile, policies that fit the firm and evidence of funding. The form should describe what the firm will do on day one, not an aspiration that depends on suppliers you have not yet chosen.
Readiness at the document stage
- Policies are approved and tailored to your actual processes, not templates
- The permissions list is correct and has been independently checked
- Forecasts, plan and policies use the same facts and names
- Important suppliers are named, not "to be selected"
Chapter 02 · Part two
Willing: management shows regulatory responsibility
A consultant can support an application. The firm's own people must own it, and answer for it.
The FCA considers how you interact with it during the application. It wants to be confident that you will be open and honest in all your dealings. If it asks for more information, you need to be proactive, for example by making staff available to deal with its queries promptly.
It also draws a line you cannot cross. It understands that you may need to change your application after submitting it, but you cannot submit a poor application and then claim to be willing, with its help, to put the deficiencies right. If you make substantive changes which show you are not ready, willing and organised, it may ask you to withdraw and reapply.
On consultants, the FCA is plain. It does not require them, and many firms find them helpful. But it expects to deal directly with the firm, and wants you to be accountable for your application and able to explain all of it. Among the weaknesses it has seen are firms overly relying on their consultant, and firms that fail to show how one person with several roles will divide their time.
Three people who should each be able to answer alone
Chief executive
Explains the permissions, the customer journey and the biggest consumer risks in plain words.
Compliance lead
Explains the complaints route, the monitoring plan and who owns each control.
Finance lead
Explains the capital position, the assumptions and where the funding comes from.
Chapter 03 · Part three
Organised: the operating model works from authorisation
Describe controls as actions with owners and evidence. Organised does not mean trading at full scale before approval.
The FCA says you must have the necessary arrangements and supporting documentation in place to comply with regulations from the day you are authorised. It will consider why you are applying now and, if it were to authorise you today, whether you could carry out the activity or whether there is still something to address.
Could you trade on day one?
- Named owners for every control in post
- Systems configured and tested for the applied-for activities
- Critical supplier contracts signed or ready to sign
- Capital paid in and evidenced
| Control area | Evidence |
|---|---|
| Governance | Board agendas, role descriptions, reporting lines, escalation routes and recorded decisions. |
| Compliance | A risk-based monitoring programme, action tracking and management reporting. |
| Financial crime | Risk assessment, customer due diligence, screening, escalation and training, as applicable. |
| Consumer outcomes | A defined target market, a vulnerable customer approach and complaints analysis, where applicable. |
| Technology and outsourcing | Incident response, service monitoring, continuity, due diligence and named operational responsibility. |
| Financial resources | Supported capital, cash flow, assumptions and a funding contingency. |
An applicant can still have a small number of steps conditional on approval, such as enabling live credentials. Make them clear, evidence them, and be sure they can be resolved without redesigning the core framework.
Chapter 04 · Join the dots
The three-document consistency test
If the business plan, forecast and policies disagree, the firm is not ready. The FCA wants to see the dots joined.
The FCA's good practice publication lists policies that are not aligned, and do not make sense when read together, as an area for improvement, often because templated policies were not designed for the firm. It also lists inaccurate financial information that hinders assessment. Test your own pack in four passes.
Four passes through your own pack
Stage 1 of 4
Read the plan
Note staff, locations, product features, fees, customers, providers and controls. Each promise has to be delivered somewhere else in the pack.
- Make a table of every commitment
- Note who is meant to deliver it
Stage 2 of 4
Test the forecast
Check the commitments appear in start dates, revenue assumptions, staff and supplier costs, and capital.
- Trace each hire and supplier into the cost lines
- Check the balance sheet balances
Stage 3 of 4
Test the policies
Check named people, systems, records, review frequency and escalation routes support each control you describe.
- Replace job titles with names
- Check the system really can do what the policy says
Stage 4 of 4
Board challenge
Ask what happens if an important provider fails, revenue is delayed or a customer is harmed.
- Record the answers in board minutes
Chapter 05 · An invented firm
Worked example: a fintech with a finished app
Technology readiness is not the same as regulatory readiness. A built product does not make an organised firm.
What would Marlow need to do? Appoint named owners for complaints and financial crime escalation, add supplier charges to the forecast, rewrite the compliance policy around what the app and its people can actually do, and have its board explain all of it.
Chapter 06 · Put it to work
Pre-submission readiness scorecard
A useful board challenge before you pay an application fee the FCA does not refund if you withdraw or are refused.
Tick a tile only when you can point to the document or the person that proves it. The FCA needs to see a firm that could operate responsibly if authorised, not one hoping to become ready during the assessment.
Are you ready to submit?
Tick each item you can evidence. Your ticks stay in this browser only.
| Question | Short answer |
|---|---|
| Can a consultant draft our application? | Yes, many firms use one. But you remain responsible for the content and must show you understand and can comply with it. |
| Does the product have to be fully live before we apply? | Not necessarily. Critical functionality, controls and dependencies must be developed and credible enough to show you will be ready on the day you are authorised. |
| Can we send drafts and improve them when the FCA asks? | No. The FCA expects final reviewed documents at submission, and says you cannot submit a poor application and rely on its help to fix it. |
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: Sample business plan
- FCA: Preparing your firm's financial information
- FCA: Apply to become an e-money or payment institution
- FCA: Apply to become a consumer investments firm
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.