FCA authorisation for new firms
Get the structure right first.

A written view of which activities you carry on and why each is or is not regulated, reached before you build. Assuming an exclusion applies is where most perimeter breaches begin, and the analysis is cheaper than the wrong answer.

The business you will actually run, described so a case officer can see how money moves and where the customer risk sits. A plan that reads like a pitch deck invites questions; a plan that reads like an operating manual answers them.

Each condition addressed on its own terms with evidence attached, rather than asserted in prose. Location, effective supervision, resources, suitability and business model are separate tests and are assessed separately.

Projections that reconcile to the business plan, with the capital requirement calculated for the permissions you are asking for — not the ones you might want later. Stress the downside case; the FCA will.

Named individuals with the relevant experience, their Statements of Responsibilities drafted, and fitness and propriety evidenced. An application where external consultants are the only compliance resource will probably be refused.

Completeness is the single biggest lever on timing you control. The determination clock does not start until the application is deemed complete, so front-loading the work is not diligence for its own sake — it is the difference between six months and considerably longer.

No. Carrying on a regulated activity without authorisation is a criminal offence under section 23 FSMA, punishable by up to two years' imprisonment and an unlimited fine. That includes marketing regulated products or services, not just transacting. The only exception is where an exemption or exclusion genuinely takes the activity outside the perimeter — and you should take perimeter guidance before assuming one applies.

The statutory periods are six months for a complete straightforward application and twelve months for a more complex one, under section 55V FSMA. The important detail is that the clock only starts once the application is deemed complete. Incomplete applications are the main source of delay, and multiple rounds of supplementary questions extend the timetable rather than running inside it.

You can apply again at any time, but a new application has to address the reasons for the refusal — the FCA expects material change, not revised paperwork. In practice most firms that receive a 'minded to refuse' notice withdraw instead, because a withdrawal is not published and a refusal is. That distinction matters for future applications and for banking and investor relationships.