How to Write an FCA Business Plan for Authorisation

An FCA business plan is the document, written for the regulator, that explains your firm's regulated activities, business model, governance, customer journey, risks and controls, and how you will meet the FCA's minimum standards. You submit it with your application for authorisation, and the FCA uses it to judge whether your firm is ready, willing and organised.

Want the full walk-through? Our free guide, Writing an FCA business plan that passes, covers the 13 areas section by section, projections that reconcile, capital and wind-down, and the mistakes that delay applications, with checklists you can tick off and a PDF to download.

What does the FCA expect in a business plan?

The FCA publishes a sample business plan, which its how to apply page says "explains each area we expect you to cover". The FCA wants a plan that is specific to your activities and shows how they match the permissions you are applying for. The FCA says the plan cannot be generic, and its list is not exhaustive: your firm type and permissions may need more. The sample sets no word or page limit. Judge length by whether the plan answers each question fully and consistently, not by a page count.

The plan is also tested against the threshold conditions, the minimum standards a firm must meet and continue to meet. Two are most relevant here. COND 2.7 asks whether the firm's business model is suitable, including its effect on consumers' interests, and COND 2.4 asks whether its resources, financial and non-financial, are appropriate.

The 13 sections of the FCA sample business plan

What goes wrong in business plans?

In September 2025 the FCA published good and poor practice for authorisation and registration applications. Its comments on business plans and policies are worth reading closely. Good practice includes:

• using the sample business plan to check that all key information is included, which the FCA says is especially relevant to small firms;
• explaining how decisions are made in the UK when operations are overseas;
• analysing why each permission requested is relevant to the intended activity; and
• embedding the Consumer Duty across policies, procedures and controls rather than treating it as a separate document.

The common weaknesses it lists are:

• policies that are not tailored to the specific business, so the FCA cannot see how they would work in practice;
• plans that do not consider all likely customer scenarios, leaving gaps for vulnerable customers;
• repeating FCA rules rather than explaining how the firm will comply in its own setting;
• focusing on risks to the firm instead of risks the business model poses to customers;
• templated policies that contradict each other; and
• unclear IT plans. The FCA says timelines and project plans for intended technology should be clear and realistic.

On staffing, the FCA warns against relying too heavily on a compliance consultant without showing you understand your own obligations: applicants are responsible for their own applications. It also flags failing to show how people with several roles will split their time, and failing to evidence staff eligibility to work in the UK.

How to write the plan, step by step

1. Start with the permission list. Write down every regulated activity you will carry on, and decide exactly which permissions you need. Everything else must tie back to them.
2. Draft the business model first. Map customers, products, revenue, third parties and money flows. Sections 5 to 13 flow from this.
3. Write each section to the sample's headings. This makes it easy for the case officer to find what they need.
4. Name people and processes, not roles in the abstract. Show who does what, when and how it is evidenced.
5. Join the plan to the forecasts. The capitalisation section must agree with the financial information. Check balance sheets balance and numbers match across documents.
6. Check the sector page for your firm type. The FCA's pages for consumer credit, investments, mortgages, payments and others list extra items, such as a wind-down plan for some firms.
7. Review as a case officer would. Look for inconsistencies, generic phrasing and gaps against the threshold conditions.
8. Submit only final, signed-off documents on Connect. The FCA says to submit only final documents and to register on Connect first.

Timing, and what happens next

The FCA says it will usually assess a complete application within six months for FSMA firms and three months for payments and e-money firms, and that an incomplete application could take up to twelve months. These tie to the statutory periods in section 55V FSMA: six months for a complete application, and twelve at most for an incomplete one. The FCA also warns that you are unlikely to be authorised straight away and that it usually has questions for applicants. If the minimum required information is missing, the FCA can reject the application without assessing it and refund the fee.

Use our authorisation checklist and the authorisation cost guide to plan for time and budget.

How MEMA can help

MEMA helps founders prepare business plans, forecasts and policies that hang together, and challenge them as a case officer would. See our FCA authorisation service or the authorisation checklist.