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Applying for FCA Authorisation in 2026: How to Ensure a Successful Application Outcome

Published 24 October 2023 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What FCA authorisation is
  2. Who needs FCA authorisation
  3. The threshold conditions the FCA applies
  4. The people the FCA assesses
  5. What the application contains
  6. Capital and financial resources
  7. What FCA authorisation costs
  8. How long FCA authorisation takes
  9. The application process step by step
  10. How the FCA reaches its decision
  11. Consumer Duty in the application
  12. Seven ways to keep the application on track
  13. After authorisation
  14. Frequently asked questions
Key takeaways
  • Any firm carrying on a regulated activity in the UK needs FCA authorisation or registration under the Financial Services and Markets Act 2000; operating without it is a criminal offence.
  • FCA application fees for 2026/27 run from £280 to £225,170 by pricing category: £1,130 for a small payment institution, £5,640 for an authorised e-money institution and £11,260 for a complex consumer credit or cryptoasset application.
  • The law gives the FCA 6 months to decide a complete application and 12 months for an incomplete one; since January 2026 the FCA targets 4 months for complete FSMA applications and 3 months for payment and e-money firms.
  • The FCA's median time to decide a new firm authorisation in Q1 2026/27 was 131 days, about 4.3 months from receipt.
  • Every applicant must meet the five threshold conditions: a UK head office, effective supervision, appropriate resources, suitability and a viable business model.
  • The FCA reviews only final, signed-off documents and expects the firm to be ready, willing and organised: able to start trading safely on the day it is authorised.

What FCA authorisation is

FCA authorisation is the legal permission to carry on regulated financial services in the UK. Section 19 of the Financial Services and Markets Act 2000 (FSMA) sets the general prohibition: no one may carry on a regulated activity in the UK unless they are authorised or exempt. Breaching it is a criminal offence, and agreements made in breach can be unenforceable against the customer.

The Financial Conduct Authority (FCA) grants most permissions. It regulates the conduct of around 35,500 firms and is the prudential supervisor, meaning it sets capital and liquidity standards, for around 34,000 of them. Banks, building societies, insurers and the largest investment firms are dual-regulated: the Prudential Regulation Authority (PRA) at the Bank of England authorises them with the FCA's consent.

Authorisation, permission and registration

Three terms are often used interchangeably. Under FSMA, a firm applies for a Part 4A permission, which lists the exact regulated activities it may carry on. Payment institutions and e-money institutions are authorised under separate regulations: the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Some businesses, such as small payment institutions and cryptoasset firms under the Money Laundering Regulations, are registered rather than authorised, which carries a lighter set of requirements.

The route matters because it sets the fee, the capital, the documents and the timetable. A firm that applies for the wrong permission has to withdraw and start again, so the first step is always to map the business model to the exact activities.

Who needs FCA authorisation

A firm needs authorisation if it carries on a specified activity, in relation to a specified investment, by way of business, in the UK. The FCA's Perimeter Guidance manual (PERG) explains each activity and the exclusions that take some businesses outside the regime. The main routes are below.

BusinessTypical activitiesLegal route
Payments and remittanceMoney remittance, payment accounts, card acquiring, payment and account information servicesPayment Services Regulations 2017
E-moneyIssuing e-money, prepaid cards, e-walletsElectronic Money Regulations 2011
Consumer creditLending, credit broking, debt counselling, debt collection, credit informationFSMA Part 4A
InvestmentsAdvising, arranging, dealing, managing investments, operating trading venuesFSMA Part 4A
InsuranceInsurance distribution and broking; underwriting (PRA-led)FSMA Part 4A
Home financeMortgage lending, arranging and advising; home reversion and home purchase plansFSMA Part 4A
Claims managementSeeking out, advising on and pursuing claimsFSMA Part 4A
CryptoassetsExchange and custody (registration now; full authorisation from 25 October 2027)Money Laundering Regulations; FSMA from 2027

Firms that may not need their own authorisation

Some businesses can operate without their own permission. An appointed representative carries on regulated activities under the responsibility of an authorised principal firm. Professional firms whose financial services are incidental to their main work may fall within an exclusion, and certain activities, such as limited network payment instruments, are excluded from the payments regime. The FCA asks firms to confirm the position before they apply, and a firm should not start regulated business while its application is under review unless an exemption applies.

Cryptoasset firms are in a transition. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 bring cryptoasset activities into FSMA. The FCA application window opened on 30 September 2026 and runs to 28 February 2027, and the new regime commences on 25 October 2027; until then the existing Money Laundering Regulations registration applies. The firm's guide to FCA cryptoasset authorisation covers that route in full.

The threshold conditions the FCA applies

The threshold conditions are the minimum standards every firm must meet at the point of authorisation and at all times afterwards. They are set out in FSMA Schedule 6 and explained in the COND sourcebook of the FCA Handbook. The case officer assesses each of them against the application.

ConditionWhat the FCA looks for
Location of officesA UK-incorporated firm has its head office and registered office in the UK. The head office is where the directors and senior managers make the day-to-day decisions, not a virtual or shared address.
Effective supervisionA group structure, ownership and close links that do not prevent the FCA from supervising the firm, and accurate information supplied on request.
Appropriate resourcesEnough capital and liquidity for the business plan, plus the people, systems and outsourcing arrangements to run it safely.
SuitabilityA fit and proper firm, judged on the honesty, competence and financial soundness of its directors, senior managers and controllers.
Business modelA model that is suitable for the activities, sustainable, and designed to give customers fair outcomes.

The FCA tests suitability using the application itself and information from other sources, including other UK and overseas regulators, its own contact centre records and complaints data. A firm meets the conditions most clearly when its business plan, financial forecasts, risk assessment and policies tell the same story in the same numbers.

The people the FCA assesses

The FCA authorises firms, but it decides largely on people. It looks for a board and management team with the knowledge and experience to run the specific business applied for, and for controllers whose source of funds and background are clear.

Senior managers and approved persons

For FSMA firms, the Senior Managers and Certification Regime (SM&CR) applies. Each person in a senior management function, such as the chief executive (SMF1), chair (SMF9) or compliance oversight (SMF16), is approved by the FCA before they start, against a Statement of Responsibilities that sets out what they are accountable for. The FCA aims to decide senior manager applications within 2 months. The firm's SM&CR guide explains the functions and the 2026 reforms.

Payment and e-money institutions sit outside the senior managers regime. Their directors and the people responsible for managing payment services are assessed for fitness and propriety as part of the authorisation itself.

The fit and proper test

The test covers three things: honesty, integrity and reputation; competence and capability; and financial soundness. Firms carry out their own checks before submitting, including criminal record checks for individual controllers, which the FCA asks to be no more than 6 months old at the date of application. Any adverse history, however minor, is best disclosed with an explanation.

Key roles to fill before submission

The FCA expects the main control functions to be in place, not promised. That normally means a money laundering reporting officer (MLRO), a compliance officer, and finance and risk leadership proportionate to the firm's size. The firm's article on hiring MLROs and heads of compliance sets out what the FCA looks for in each role.

The conduct rules

Most staff in FSMA firms are bound by the individual conduct rules, which grew out of the Parliamentary Commission on Banking Standards' work after the 2008 financial crisis. Every individual must act with integrity; act with due skill, care and diligence; be open and cooperative with the FCA, the PRA and other regulators; pay due regard to the interests of customers and treat them fairly; observe proper standards of market conduct; and act to deliver good outcomes for retail customers.

What the application contains

Applications are made through Connect, the FCA's online system, using the forms for the route applied for. The core pack is similar across sectors.

  • Regulatory business plan: the products, target customers, distribution channels, revenue model, organisational structure and how each regulated activity will be carried on. The FCA publishes a sample business plan showing the areas it expects.
  • Financial forecasts: normally three years of projected balance sheets, income statements, cash flow and capital calculations, with the assumptions behind them and a stress scenario.
  • Wind-down plan: how the firm would close in an orderly way, with the cost and time to do so and the triggers that would start it.
  • Policies and procedures: compliance monitoring, anti-money laundering and counter-terrorist financing, risk management, complaints handling, conflicts of interest, outsourcing, information security and business continuity, written for this firm rather than adapted from a template.
  • Governance: board composition, committee terms of reference, the reporting lines of the control functions and a responsibilities map where SM&CR applies.
  • People and controllers: individual forms for senior managers or directors, controller forms for anyone holding 10% or more, CVs, references and criminal record checks.
  • Consumer Duty evidence: where the firm serves retail customers, how its products, pricing, communications and support will deliver good outcomes.

The FCA reviews only final documents that the board has approved. Drafts, placeholders and unexplained inconsistencies between documents lead to questions that extend the assessment, so the pack is best checked end to end before submission. The firm's free FCA application gap checker runs that check against the FCA's expectations.

Capital and financial resources

Every firm must hold adequate financial resources, and some routes set a fixed minimum on top. The FCA looks at both: the legal minimum, and whether the firm can meet its liabilities as they fall due across the forecast period, including under stress. It expects the funding to be in place, with a clear and verified source.

Firm typeMinimum initial capital
Authorised payment institution: money remittance only€20,000
Authorised payment institution: payment initiation services€50,000
Authorised payment institution: other payment services€125,000
Authorised electronic money institution€350,000
Investment firmsSet by the MIFIDPRU sourcebook according to the permissions held
Consumer credit firmsNo fixed minimum for most firms; adequate resources assessed on the business plan

Payment and e-money capital is fixed in euros by the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Beyond the minimum, the FCA expects most new firms to show they can fund their operating costs for a sustained period without relying on revenue that has not yet been earned.

What FCA authorisation costs

The FCA charges a one-off application fee, paid through Connect when the application is submitted. The fee is set by the type of application, in pricing categories published on the FCA's application fees page (last updated 13 July 2026).

CategoryFeeTypical applications
1£280Consumer buy-to-let firms with a Part 4A permission; community finance organisations
2£560Limited permission consumer credit; Money Laundering Regulations registration; variation within the same fee-block
3£1,130Small payment institution; small e-money institution; account information service provider; straightforward consumer credit
4£2,820Authorised payment institution (certain services); straightforward investment, insurance intermediary and corporate finance firms
5£5,640Authorised e-money institution; authorised payment institution (most services); moderately complex consumer credit
6£11,260Complex consumer credit; claims management; cryptoasset businesses; most MiFID investment managers
7£28,150Banks and insurers
8 to 10£56,300 to £225,170Trading venues and recognised investment exchanges

The fee is not refunded if the application is withdrawn or refused; it is refunded only if the FCA rejects the application at the outset for missing minimum information. Once authorised, the firm pays annual periodic fees based on its fee-block and the size of its business, plus levies such as the Financial Ombudsman Service and, where relevant, the Financial Services Compensation Scheme. The full cost of a project also includes capital, key hires, systems, professional indemnity insurance where required, and audit.

How long FCA authorisation takes

FSMA section 55V gives the FCA 6 months to decide a complete application and 12 months from receipt to decide an incomplete one. In July 2025 the FCA announced faster targets, measured from January 2026, and it reports its performance against them each quarter.

ApplicationCompleteIncomplete
Statutory maximum (FSMA s.55V)6 months12 months
FCA target: new FSMA firm4 months10 months
FCA target: payment and e-money firms3 months10 months
FCA target: senior manager approval2 months2 months

In Q1 2026/27 the FCA's median time to determine a new firm authorisation was 131 days, about 4.3 months, with a quarter of cases decided within 91 days. For payment and e-money authorisations and registrations the median was 219 days, about 7.2 months. An application counts as complete only once the FCA has every piece of information it needs, so the clock in practice runs from the point the last answer is accepted. The firm plans payment and e-money authorisations at 6 to 8 months from submission, which matches that published median and allows for the case officer's rounds of questions.

The application process step by step

  1. Confirm the permissions. Map each product and revenue line to the regulated activities, using PERG, and decide the route: authorisation, registration or appointed representative status.
  2. Use pre-application support where available. The FCA's pre-application support service (PASS) offers early meetings to some innovative and early-stage firms.
  3. Build the firm before the application. Appoint the directors and key people, put the capital in place, sign the main outsourcing contracts and open the bank and safeguarding accounts the plan relies on.
  4. Prepare and sign off the pack. Write the business plan, forecasts, wind-down plan and policies, and have the board approve them as final.
  5. Register on Connect and submit. Complete every form, attach every document, and pay the fee. The FCA confirms receipt with a reference number.
  6. Work with the case officer. The FCA allocates a case officer who checks the application against the threshold conditions and with other regulators, issues questions and may hold calls or meetings. Prompt, complete answers keep the assessment moving.
  7. Receive the decision. On approval the firm appears on the Financial Services Register and receives a letter setting out its permissions and any requirements attached to them.

Ready, willing and organised

The FCA describes the applicant it wants to see in three words. Ready means the firm has read the FCA's published material and submits final documents. Willing means it is open with the case officer and answers questions quickly and fully. Organised means its arrangements are in place, so that it could start providing its products and services on the day it is authorised. The FCA's good and poor practice publication gives examples of each.

How the FCA reaches its decision

Where the case officer has concerns, the FCA gives informal feedback first, and the firm can supply more information, change its plan or withdraw and reapply later when ready.

OutcomeWhat it meansFee
ApprovedFirm added to the Register with its permissionsNot applicable
RejectedReturned at the outset for missing minimum information; can be resubmitted at any timeRefunded
WithdrawnFirm ends the assessment; can reapply when readyNot refunded
RefusedFormal decision that the threshold conditions are not metNot refunded

If the case officer recommends refusal, an FCA executive decision-maker reviews the case and may issue a Warning Notice. The firm can make written representations within the period stated in the notice. If the decision-maker still refuses, a Decision Notice follows, which the firm can refer to the Upper Tribunal; otherwise the FCA issues a Final Notice and may publish it. A firm can withdraw during the informal feedback stage, which avoids a formal refusal on its record.

Consumer Duty in the application

The Consumer Duty has applied to open products since 31 July 2023 and to closed products since 31 July 2024. It requires firms serving retail customers to act to deliver good outcomes: to act in good faith, avoid foreseeable harm and enable customers to pursue their financial objectives.

The FCA now expects applicants to show how the Duty is built into the business from the start, across its four outcomes:

  • Products and services: designed for an identified target market.
  • Price and value: a fair value assessment that compares the price with the benefits.
  • Consumer understanding: communications tested so that customers can make informed decisions.
  • Consumer support: support throughout the product's life, including for customers in vulnerable circumstances.

A short board-approved Consumer Duty framework, with the management information the board will review, is the clearest way to evidence this in the application.

Seven ways to keep the application on track

  1. Know the rules that apply. Read the threshold conditions and the sourcebooks for the route before drafting.
  2. Confirm the permissions match the business. Every product and revenue line in the plan should map to a permission applied for.
  3. Appoint experienced people. Directors, the compliance officer and the MLRO should have direct experience of the activity applied for.
  4. Write policies for this firm. Detailed procedures that reflect the actual products, customers and systems carry far more weight than generic templates.
  5. Be open with the case officer. Disclose anything relevant early, with an explanation, and answer questions in full.
  6. Fund the plan properly. Hold capital and liquidity for the forecast period with a margin for slower growth.
  7. Put controls in place before submission. Compliance monitoring, financial crime controls and outsourcing oversight should operate from the first day.

After authorisation

Authorisation does not expire, but it carries continuing obligations. The firm must meet the threshold conditions at all times and keep the FCA informed.

  • Regulatory reporting: returns submitted through RegData on the schedule set for the firm's permissions, such as financial, capital, complaints and, for payment and e-money firms, monthly safeguarding returns under CASS 15.
  • Fees and levies: annual periodic fees and levies, invoiced each year.
  • Notifications: advance notice of new controllers, material outsourcing and changes to the business. Adding or removing activities needs a variation of permission, and a new owner of 10% or more needs FCA change of control approval before completion.
  • Use of permissions: the FCA can cancel a permission that has not been used for 12 months.
  • Early supervision: some new firms are offered support through the FCA's Early and High Growth Oversight programme in their first years.

Serving customers outside the UK

UK firms lost EU passporting rights on 31 December 2020. FCA authorisation covers the UK only; to serve customers in the European Economic Area a firm needs authorisation in an EU member state, and other countries apply their own licensing rules.

Frequently asked questions

How long does FCA authorisation take in 2026?

The law allows 6 months for a complete application and 12 months for an incomplete one. The FCA targets 4 months for complete FSMA applications and 3 months for payment and e-money firms, and its median for new firms in Q1 2026/27 was 131 days.

How much is the FCA application fee?

Fees run from £280 to £225,170 depending on the pricing category. A small payment institution pays £1,130, an authorised e-money institution £5,640 and a complex consumer credit or cryptoasset business £11,260.

Can I start trading while my FCA application is being assessed?

No. A firm must not carry on regulated activities until it is authorised, unless an exemption or exclusion applies, such as acting as an appointed representative of an authorised firm.

What is the difference between FCA authorisation and registration?

Authorisation grants permission to carry on regulated activities and brings the full set of FCA rules. Registration, used for small payment institutions and cryptoasset firms under the Money Laundering Regulations, covers a narrower scope with lighter requirements.

Can an FCA authorisation be transferred to a new owner?

No. Authorisation belongs to the firm, so a buyer acquires the authorised company itself and needs FCA change of control approval before completion.

What happens if the FCA refuses my application?

The FCA issues a Warning Notice, the firm can make written representations, and a Decision Notice can be referred to the Upper Tribunal. The fee is not refunded, and the firm can reapply once it has addressed the reasons.

Does FCA authorisation let me serve EU customers?

No. Passporting ended on 31 December 2020, so a UK firm needs authorisation in an EU member state to serve customers in the European Economic Area.

Do I need a UK office to be authorised by the FCA?

Yes. A UK-incorporated firm must have its head office and registered office in the UK, and the head office must be where the directors and senior managers make day-to-day decisions.

References

  1. Financial Services and Markets Act 2000 (legislation.gov.uk)
  2. FCA: How to apply for authorisation
  3. FCA: Authorisation and registration application fees
  4. FCA: FCA sets faster targets for authorisations (15 July 2025)
  5. FCA: Authorisations operating service metrics 2026/27 Q1
  6. FCA Handbook: COND Threshold Conditions
  7. FCA: Good and poor practice in authorisation and registration applications
  8. FCA: Refusal process for authorisation applications

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations since 2013, including payment institution licences for Nexpay, Orbital and Global Send, e-money licences for Dzing Finance and Hryze, and a variation of permission for Moneliq. The firm prepares the full application, from the regulatory business plan and financial forecasts to the policies and key appointments, and manages the case officer's questions through to the decision.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.