Variation of Permissions (VoP)
Need to add new regulated activities or expand your FCA permissions? We help you navigate the Variation of Permissions process, ensuring your application meets FCA requirements and positions your firm for successful expansion.
What is a Variation of Permissions?
An application to the FCA to request additional permissions, remove certain permissions, or modify existing ones to support your business growth
Why Firms Need Variation of Permissions
When your business wants to expand into new regulated activities, you cannot simply start those activities. You must first obtain the appropriate FCA permissions through the VOP process.
Launch New Business Lines
Add completely new regulated activities to your authorization
Conduct Additional Activities
Expand existing permissions to cover more product types or services
Add Client Types
Extend permissions to serve new customer segments or markets
Common Permission Change Requests
Examples of when firms typically need a Variation of Permissions
Adding New Products
Insurance broker wants to add mortgage broking
A firm with insurance permissions cannot make mortgage introductions without first obtaining those specific permissions
Expanding Services
Credit broker adding consumer credit lending
Moving from arranging credit to providing credit directly requires additional permissions
New Client Segments
Retail-only firm adding corporate clients
Expanding from retail customers to professional clients may require permission updates
Advisory Services
Non-advisory firm adding advice
Moving from execution-only to providing personal recommendations requires authorization
Additional Investments
Adding investment management permissions
Firms wanting to manage client investments need specific MiFID permissions
Removing Permissions
Streamlining business activities
Removing unused permissions can reduce regulatory burden and costs
The VOP Application Process
Understanding the steps and requirements for successful permission changes
Business Plan Update
Revise your business plan to explain new activities
- Why you want the new permissions
- How the business model will work
- Demonstration of expertise and capability
- Resource and capital adequacy
- Risk assessment for new activities
Online Application
Complete FCA's online VOP application form
- Updated regulatory documentation
- Revised organizational structure
- New or amended permissions requested
- Supporting evidence and rationale
- Applicable fees payment
SM&CR Considerations
Assess impact on Senior Managers regime
- Additional SMF approvals may be needed
- Limited Scope status may change
- Prescribed Responsibilities updates
- Statement of Responsibilities revisions
- New Certification requirements
Regulatory Implications
Understand knock-on compliance effects
- Financial category changes
- Increased capital requirements
- Enhanced reporting obligations
- Additional PI insurance coverage
- New compliance monitoring needs
How Much Does a Variation of Permission Cost?
The rule of thumb that a VoP costs 50% of the standard application fee is only true in some circumstances. What you actually pay depends on what the variation does to your permission.
FCA application fees for a variation of permission are set out in FEES 3 Annex 16R, with the general fee categories themselves defined in FEES 3 Annex 1R. There is no single VoP fee. Instead, the fee depends on whether the variation adds business in a fee-block the firm has never held, extends what it already does within a fee-block it already holds, or only removes permissions.
Adding a new fee-block
If the variation adds business in a fee-block the firm did not previously hold, the fee is 50% of the highest applicable fee category for that application. Where a variation adds several new fee-blocks at once, it is 50% of the highest category involved, not the sum of each.
Extending within an existing fee-block
If the variation increases scope inside a fee-block the firm already holds, the 50% rule does not apply. Instead it is a flat category charge: Category 1 for fee-blocks A.1, A.3, A.4 and A.5, or Category 2 (£560) for other fee-blocks.
Reducing scope only
If the variation only reduces scope, with no other increases, there is no fee. Note the qualifier: an application that removes one permission and adds another gets no credit for the removal, so the addition is still priced in full.
The FCA's Ten Fee Categories
These are the general application fee categories under FEES 3 Annex 1R that the variation fee rules above are calculated against.
Worked example
A firm already authorised for other regulated activities applies to add mortgage broking, entering the Category 4 fee-block for the first time. Because this fee-block is new to the firm, the fee is 50% of the Category 4 charge: 50% of £2,820, which is £1,410.
Most financial advisers, mortgage brokers and general insurance intermediaries fall into Category 4 for these purposes, which is the FCA's own description on its fees page. For consumer credit activities, a full permission application falls into Category 3, 5 or 6 depending on the specific permission applied for, while a limited permission application falls into Category 2.
A Form A application for a senior manager submitted as part of a wider application, such as a variation, is not charged separately. Most firms in the 'A' fee-blocks also pay a minimum annual periodic fee of £2,000 to the FCA, and adding a new fee-block through a variation creates a further periodic fee liability for that block going forward.
How Long Does a Variation of Permission Take?
The statutory deadline is a backstop, not a forecast. The FCA's own published performance data show most variations are determined far sooner.
The statutory position is set out in section 55V of the Financial Services and Markets Act 2000. Section 55V(5)(b) applies the same determination periods to a variation of a Part 4A permission as apply to a new application: six months to determine a complete application, or twelve months if the application is incomplete when submitted. Where the variation relates only to insurance distribution activity, section 55V(9) shortens the complete-application period to three months.
The FCA has also started measuring itself against faster voluntary targets. Its own material describes these as proposed statutory deadlines that have been consulted on by Government, not deadlines currently in force. Until legislation changes, the statutory deadline for a variation remains six months for a complete application (three months for insurance distribution activity only), or twelve months for an incomplete one. If the FCA does not determine an application within the statutory period, SUP 6.3.38A confirms the application is not deemed granted: silence does not equal approval.
These figures come from the FCA's Authorisations operating service metrics for 2025/26 Q4, covering January to March 2026 and published on 21 May 2026. Measured against the FCA's newer, faster and currently non-statutory internal target, the result for the quarter was 97.4%.
Determination time also varies by sector. In the same quarter, median days to determination were 20 days for Credit and Lending limited permission applications, 22 days for other Credit and Lending applications, 29 days for Consumer Investments, 50 days for Wholesale, and 71 days for Insurance, the slowest sector measured.
The honest summary: the statutory backstop is six months, but the realistic range for a well-prepared variation runs from around two weeks to about eleven weeks, depending on sector and how complete the application is when it is submitted. Speak to our team via a consultation about a realistic timeline for your specific application.
Source: FCA, Authorisations operating service metrics 2025/26 Q4, January to March 2026, published 21 May 2026. Figures relate to that quarter only.
Part 4A Permission and the Practical Mechanics
What a variation can and cannot do, how it is submitted, and how it differs from cancellation or a requirement
A variation of permission is an application under FSMA to change a firm's existing Part 4A permission. It is only available to a firm that is already authorised. A firm with no existing permission at all needs a full FCA authorisation application instead of a variation. For a broader walkthrough of the process, see our variation of permission explainer.
What a variation of permission application form covers
There is no separate downloadable FCA variation of permission application form. Applications are submitted online through the FCA's Connect system, the same portal used for authorisation and permission applications generally. SUP 6.3.1A sets out the three things a variation can do: allow the firm to carry on further regulated activities, reduce the number of regulated activities it is permitted to carry on, or vary the description of its regulated activities, including removing or varying any limitation attached to them.
Talk to your supervisor first
SUP 6.2.6 expects a firm proposing a substantial variation to discuss it with its supervisory contact at the FCA before applying. Early engagement tends to surface concerns before they become a formal query during the application itself.
The SMCR consequence that gets missed
Under SUP 6.3.9G, taking on new activities through a variation can mean a firm becomes subject to the Senior Managers and Certification Regime for the first time, or moves from one type of SMCR firm to another. That changes which senior manager functions need approval and widens who falls within the Code of Conduct. It is a consequence firms often only discover late in the process, when it is harder to plan around.
Variation, cancellation or requirement
A variation is not the only route available. Cancelling a permission entirely is a separate process under SUP 6.4, used when a firm is stopping regulated activity altogether rather than adjusting it. A firm can also apply to impose, vary or cancel a requirement under SUP 6.3.2A, which can run alongside a variation application rather than instead of it. Choosing the right mechanism, or combination of mechanisms, affects both the fee and the timeline.
Critical: Do Not Start Before Approval
You cannot start the activities that you have requested under the Variation of Permissions application until your application is approved by the FCA
Conducting regulated activities without the appropriate permissions is a criminal offense. Wait for FCA approval before launching new services, even if your application is pending.
How MEMA Supports Your VOP Application
Comprehensive support from planning through FCA approval and beyond
Strategic Planning
Understanding implications before you apply
Includes:
- Permission requirement analysis
- Regulatory impact assessment
- SM&CR implications review
- Cost and resource planning
- Timeline and strategy development
Application Preparation
Professional application support
Includes:
- Online application completion
- Revised business plan drafting
- Compliance documentation suites
- Supporting evidence compilation
- FCA query management
Post-Approval Support
Implementing your new permissions
Includes:
- Updated policies and procedures
- Compliance monitoring frameworks
- Staff training programs
- Ongoing regulatory advisory
- Implementation guidance
Expert VOP Guidance
Our team of ex-regulators, Big 4 consultants, and fintech specialists brings deep experience guiding firms through complex permission changes
Sectors We Support
This service is available for firms across these regulated sectors
Related FCA Guidance
Deeper reading on the regulatory framework behind permission variations.
Full vs Limited Permission
When to apply for full FCA permission versus limited permission.
HandbookPERG: Perimeter Guidance
Understanding which new activities require additional FCA permissions.
ImplementationFCA Authorisation Preparation
Evidence and documentation requirements that also apply to VOP applications.
Frequently Asked Questions
Common questions about FCA variation of permission applications
How much does an FCA variation of permission cost?
How long does a VoP take?
Do I need a VoP or a new authorisation?
Is there a fee to remove permissions?
How do I submit a variation of permission application?
Will a VoP change my SMCR obligations?
Ready to Expand Your FCA Permissions?
Contact our VOP specialists to discuss your permission requirements and business growth plans
📞 Phone: 0330 133 0811
📧 Email: contact@memaconsultants.com