Variation of Permission: the scope decision before launch
The FCA tells authorised firms to review current permissions before a proposed change and not to start requested activities until approval.
Read the guideGET AUTHORISED
Expand Your Business • Add New ActivitiesAdd, remove or amend permissions on an existing Part 4A permission set.
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.
SERVICE OVERVIEW
Extend or reshape your permissions without losing sight of the controls around the change.
Authorised firms adding products, clients, activities or business lines. A proportionate variation strategy with aligned governance, documentation and evidence.
Depends on what is changing
Under FSMA the FCA must decide within 6 months of receiving a complete application, or within 12 months of receiving an incomplete one.
An application to the FCA to request additional permissions, remove certain permissions, or modify existing ones to support your business growth
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.
Add completely new regulated activities to your authorisation
Expand existing permissions to cover more product types or services
Extend permissions to serve new customer segments or markets
The scope of a VoP depends on what changes in the model and customer journey.
New product
Assess the permission, risk and control implications.
New client type
Align the proposition, disclosures and governance.
New regulated activity
Map the perimeter and operating capability.
Removing or narrowing
Manage the change and ongoing obligations.
Examples of when firms typically need a Variation of Permissions
Insurance broker wants to add mortgage broking
A firm with insurance permissions cannot advise on or arrange regulated mortgage contracts without first obtaining those permissions
Credit broker adding consumer credit lending
Moving from arranging credit to providing credit directly requires additional permissions
Retail-only firm adding corporate clients
Expanding from retail customers to professional clients may require permission updates
Non-advisory firm adding advice
Moving from execution-only to providing personal recommendations requires the relevant advising permission
Adding investment management permissions
Firms wanting to manage client investments need specific MiFID permissions
Streamlining business activities
Removing unused permissions can reduce regulatory burden and costs
Understanding the steps and requirements for successful permission changes
Revise your business plan to explain new activities
Complete FCA's online VOP application form
Assess impact on Senior Managers regime
Understand knock-on compliance effects
Comprehensive support from planning through FCA approval and beyond
Understanding implications before you apply
Professional application support
Implementing your new permissions
What the FCA expects, and the evidence behind it.
Permission scope
Define the activity and why the current permission is insufficient.
Business plan
Update the model, forecasts, customers and delivery approach.
Controls
Refresh policies, procedures, systems and oversight.
Senior management
Show accountability for the proposed change.
A VoP starts with a clear account of what is changing and why the current permission set no longer fits.
The application and the firm's controls should move together.
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.
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. Credit-related permissions follow their own rules: most are charged at 100% of the highest relevant category, while adding a limited permission to an existing limited permission carries no fee.
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.
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.
These are the general application fee categories under FEES 3 Annex 1R that the variation fee rules above are calculated against.
A firm already authorised for other regulated activities applies to add mortgage broking, entering fee-block A.18 (home finance intermediation, pricing category 4) 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 (see the FCA fee calculator), and adding a new fee-block through a variation creates a further periodic fee liability for that block going forward.
The route from scoping your permissions to a decision. The FCA's part of it is fixed; the preparation before it is where applications are won or lost.
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.
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.
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.
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.
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.
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.
Our team of ex-regulators, Big 4 consultants, and fintech specialists brings deep experience guiding firms through complex permission changes
The firm faced a lapse in its FCA permissions, and its in-flight application was no longer the right route. Pushed to a decision, it risked an adverse outcome on the firm's regulatory record.
The firm's regulatory record protected, with a mapped route back to authorisation for when it is ready.
Deeper reading on the regulatory framework behind permission variations.
This service is available for firms across these regulated sectors
End-to-end support across the full regulatory lifecycle.
Common questions about FCA variation of permission applications
There is no downloadable FCA variation of permission form to fill in. A firm applies online through the FCA's Connect system, the same portal used for authorisation applications, and the FCA accepts a paper submission only in rare cases where Connect cannot be used. The application sets out the permissions requested and is supported by an updated business plan, evidence of resources and revised policies and procedures.
It depends on what the variation does, not a flat 50% rule. Adding a fee-block the firm does not already hold costs 50% of the highest applicable FCA fee category for that application. Extending scope within a fee-block the firm already holds is a flat charge instead: 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, with no other increase, carries no fee. The rules sit in FEES 3 Annex 16R. Credit-related permissions follow their own rules: most are charged at 100% of the highest relevant category, while adding a limited permission to an existing limited permission carries no fee.
The statutory backstop under section 55V FSMA is six months for a complete application, or twelve months if incomplete (three months where the variation relates only to insurance distribution activity). In practice the FCA moves faster: in its Authorisations operating service metrics for 2025/26 Q4 (January to March 2026), the median determination time for a variation of permission was 32 calendar days, with an upper quartile of 77 days. All variations that quarter were determined within the statutory deadline.
A variation of permission is only available to a firm that already holds FCA authorisation and wants to change its existing Part 4A permission, whether by adding activities, reducing them, or varying how they are described. A firm with no existing FCA permission at all cannot use a variation: it needs a full Part 4A authorisation application instead. Both processes are submitted through the same Connect system but sit under different provisions of FSMA.
No fee applies to an application that only reduces the regulated activities a firm is permitted to carry on. There is an important qualifier, however: if an application removes one permission while also adding another, the removal earns no credit against the fee for the addition. The addition is priced exactly as it would be if the removal were not part of the same application.
Variation of permission applications are submitted online through the FCA's Connect system rather than on a downloadable paper form. Before submitting a substantial variation, SUP 6.2.6 expects the firm to discuss the proposed change with its supervisory contact at the FCA first. A senior manager Form A submitted as part of the same wider application is not charged separately from the variation fee.
It can. Under SUP 6.3.9G, taking on new regulated activities through a variation may 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 can change which senior manager functions need approval and widen who falls within the Code of Conduct.
There is no downloadable FCA variation of permission form to fill in. A firm applies online through the FCA's Connect system, the same portal used for authorisation applications. The FCA accepts a paper submission only in rare cases where a firm cannot use Connect. If your change is substantial, SUP 6.2.6G says you should discuss it with your supervisory contact at the FCA as early as possible before you apply.
Under section 55V of FSMA the FCA has six months to determine a complete application and twelve months if the application is incomplete (three months where it relates only to insurance distribution). In practice most variations are decided faster. The timeline section on this page gives the FCA's published figures.
The fee depends on what the variation does and on the firm's pricing category. An application that only reduces scope carries no fee. The rules are in FEES 3 Annex 16R, the amount for each pricing category is in FEES 3 Annex 1AR, and both are summarised on the FCA application fees page. Our cost section explains the rules. If you want help with the application, book a consultation.
Contact our VOP specialists to discuss your permission requirements and business growth plans
Phone: 0330 133 0811
Email: contact@memaconsultants.com
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