Variation of Permissions (VoP)

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 authorisation

• 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

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. 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.

• 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.

• Category 1
  £280
• Category 2
  £560
• Category 3
  £1,130
• Category 4
  £2,820
• Category 5
  £5,640
• Category 6
  £11,260
• Category 7
  £28,150
• Category 8
  £56,300
• Category 9
  £112,590
• Category 10
  £225,170

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.

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.

• 32 days
  Median determination time
  FCA metric R5.1, Q4 2025/26
• 12 days
  Lower quartile
  Fastest quarter of applications
• 77 days
  Upper quartile
  Slowest quarter of applications
• 100%
  Determined within the statutory deadline
  Zero cases closed late

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.