Variation of Permissions
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
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
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