Variation of Permission: the scope decision before launch

At a Glance

The FCA's Variation of Permission page, last updated on 13 February 2026, explains when authorised firms should consider applying and the statutory decision periods involved.

The FCA tells an authorised firm to review its current permissions and decide whether it needs to vary them before starting a new line of business, regulated activity, product or client type. The firm cannot start the activities requested in the application until approval. MEMA therefore treats the permission decision as a launch dependency, not a late-stage formality.

The guidance is relevant whenever an authorised firm is considering one of those changes. MEMA recommends identifying the permission owner, commercial dependency and control-readiness evidence early, while keeping that internal planning advice distinct from the FCA's published requirements.

The Decision Firms Need to Make

Variation of Permission

The FCA says firms should review current permissions before the proposed change, must use Connect except in rare circumstances and cannot start the requested activities before approval. For an FSMA application, the statutory decision period is the earlier of six months from receiving a complete application or twelve months from receiving an incomplete application.

The different statutory periods make application completeness commercially relevant, but they are not promised turnaround times. MEMA recommends separating the FCA's published periods from any internal forecast, confirming Connect access and recording which launch steps must remain blocked while the application is undecided.

Who This Guide Is For

The FCA guidance applies across authorised firms considering whether a proposed line of business, regulated activity, product or client type needs a permission change. The decisive question is the firm's existing permission and proposed activity, not a generic sector label.

The FCA says only authorised firms can apply and directs each firm to review its own current permissions before the proposed change. The published guidance does not support a separate claim about small-firm exemptions or materiality thresholds, so the article does not infer one.

Evidence to Prepare

MEMA recommends mapping the proposed activities against the current permission, recording the scope judgement and assigning owners for the application and launch dependency. The evidence plan should be checked against the FCA's current guidance and the facts of the firm's request, without presenting MEMA's control-readiness framework as an FCA requirement.

MEMA recommends reflecting the FCA's stated decision periods in the commercial plan, keeping customer communications and operational access aligned to the existing permission until approval. Internal targets should identify dependencies and review points but must not be described as FCA deadlines.

How to Prepare

MEMA Practical View

MEMA recommends that boards treat the permission assessment as part of the commercial launch decision. The board should see the proposed activity, current permission, unresolved scope questions, approval dependency and evidence of control readiness, while recognising that the control-readiness framework is MEMA advice rather than wording from the FCA guidance.

MEMA recommends planning explicitly for the application workload and the FCA's stated decision periods. Governance reporting should distinguish source facts from internal assumptions, record the accountable owner and show which launch steps remain conditional on approval.

Source Evidence

Disclaimer

This article is for general information only and does not constitute legal or regulatory advice. Firms should assess the application of regulatory requirements by reference to their permissions, products, customers and operating model.

How MEMA Can Help

MEMA can help firms translate regulatory change into practical controls, policies, monitoring activity and board evidence. Book a free scoping call to discuss what this development means for your firm.

MEMA can provide ongoing FCA compliance support for firms reviewing how the development affects their permissions, products and operating model.

For the wider permissions journey, read our guide to FCA authorisation timelines and planning.