MEMA Scope · Assessment

Do investment platforms and wealth-tech firms need FCA authorisation?

A digital platform that lets customers buy, sell and hold investments such as funds or shares, sometimes with model portfolios or automated advice. Review the initial view below and answer a few questions to refine it.

Personalised to your business
FCA rule references
Follow-up questions available

Initial viewProvisional assessment

Potential regulated activity identified

Operating an investment platform may require FCA authorisation

Platforms usually need permissions to arrange deals and, where they hold customer assets, to safeguard and administer them.

Route to consider: Direct authorisation (full permission)

Investment Arranging / DealingSafeguarding and Administering Investments (Custody)

Why this was flagged

1Operating a platform on which investments are bought and sold involves arranging, and often dealing, activities.
2Holding customer assets or cash on the platform brings client money and custody rules.

Questions still to resolve

Answer to refine the view. The result updates as you go.

?
Do you give personalised recommendations, including through automated guidance?
?
Does the platform invest customers’ money for them under a mandate, for example through model portfolios, without approval for each trade?
?
Does the platform match buyers and sellers of investments itself, operating a market or trading venue?A trading venue is a separate regulated activity.
?
Will an authorised firm be the legal service provider to your customers, with you only supplying technology?

Regulatory basis to examine

RAO Art.25 Arranging deals in investmentsArranging deals in investments RAO Art.40 Safeguarding and administering investmentsSafeguarding and administering investments PERG 13 Investment services and activities and investment firmsPERG 13: investment services and activities CASS 7 Client money rulesClient money rules

Your next steps

1Map which regulated activities the platform performs and who is the customer’s service provider
2Decide on custody and client money arrangements
3Determine your prudential category and capital
4Prepare financial promotions approvals for your app

Where applications for this model most often fall short

Client money and asset reconciliation design
Operational resilience and outsourcing plan
A clear target market and Consumer Duty outcomes evidence

Book a free scoping call

This is an initial indication from published FCA material, not an FCA determination or legal advice.

MEMA Compass

Ask a follow-up about your assessment

How Compass helps

Ask about an activity, exclusion or FCA requirement. Answers come only from vetted profiles, FCA Handbook and legislation extracts and MEMA guidance, and every answer cites its source.

Continue exploring

Recommended MEMA resources

Need an expert view?

Discuss your business model and authorisation route. Your assessment is added to the booking if you choose.

Book a free scoping call

Continue with a more detailed readiness assessment

If authorisation is required, check the firm’s governance, policies, resources and application preparedness.

Will the FCA Authorise Us?

MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.

About this business model

A digital platform that lets customers buy, sell and hold investments such as funds or shares, sometimes with model portfolios or automated advice.

Platforms usually need permissions to arrange deals and, where they hold customer assets, to safeguard and administer them.

This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.

Investment platform or wealth-tech: frequently asked questions

Does an investment app need FCA authorisation?

An app that arranges transactions in investments, holds customer assets or gives personalised recommendations is likely to need authorisation, or must work through an authorised firm that provides the regulated service.

Is robo-advice regulated?

Personalised automated recommendations can be advising on investments, which is a regulated activity under RAO Art.53.

What could change the answer for investment platforms and wealth-tech firms?

Platforms usually need permissions to arrange deals and, where they hold customer assets, to safeguard and administer them. It can change depending on the answers to questions such as: Do you give personalised recommendations, including through automated guidance? Does the platform invest customers’ money for them under a mandate, for example through model portfolios, without approval for each trade? Does the platform match buyers and sellers of investments itself, operating a market or trading venue? Will an authorised firm be the legal service provider to your customers, with you only supplying technology?

Which FCA rules should investment platforms and wealth-tech firms look at first?

Start with: Arranging deals in investments; Safeguarding and administering investments; PERG 13: investment services and activities; Client money rules. This is an initial view from published FCA material, not an FCA determination.

What are the first steps for investment platforms and wealth-tech firms?

Map which regulated activities the platform performs and who is the customer’s service provider. Decide on custody and client money arrangements. Determine your prudential category and capital. Prepare financial promotions approvals for your app.

Businesses we check

MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.