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FCA Compliance Consultant: How to Choose the Right Consulting Partner (2026)

Published 28 December 2019 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a regulatory consulting partner does for a payment or e-money firm
  2. Which firms benefit from a specialist partner
  3. What the FCA expects from applicants, whoever drafts the application
  4. Eight criteria for choosing a regulatory consulting partner
  5. Questions to ask in the first meeting
  6. How engagements are usually structured
  7. Regulator costs and capital to budget for
  8. A realistic timeline
  9. What marks out a strong partner
  10. How Buckingham Capital Consulting approaches this work
  11. Frequently asked questions
Key takeaways
  • The FCA decides complete payment and e-money applications within 3 months and incomplete ones within up to 12 months, so the adviser's main job is a complete, firm-specific submission.
  • The FCA deals directly with the applicant, not its adviser: the main contact must be an individual at the firm, and the FCA may interview the MLRO or finance director.
  • The FCA states that policies and procedures submitted with an application should not be generic templates; drafting must reflect the firm's own model.
  • Authorisation is one part of the work: an authorised EMI needs €350,000 initial capital, a safeguarding account and payment scheme access, all planned alongside the application.
  • Since 7 May 2026, CASS 15 requires an annual safeguarding audit and a monthly safeguarding return, so support after authorisation belongs in the selection.
  • Track record can be checked independently: every client firm an adviser cites appears on the FCA Register with its status and permissions.

What a regulatory consulting partner does for a payment or e-money firm

A regulatory consulting partner helps a payment or e-money business obtain FCA authorisation and then operate within the rules. For most firms the engagement covers four things: choosing the right licence, preparing the application, arranging the banking and payment infrastructure the licence depends on, and running compliance once the firm is live.

The choice matters because the FCA assesses the firm, not the adviser. A strong partner leaves the directors, the compliance officer and the MLRO (money laundering reporting officer, the person responsible for anti-money laundering controls) able to explain every part of the application in their own words.

StageWhat the partner delivers
Licence choiceA written view on whether the model needs an authorised payment institution (API), small payment institution (SPI), e-money institution (EMI) or account information registration
ApplicationBusiness plan, three-year financial forecasts, capital and safeguarding methodology, governance map and firm-specific policies
InfrastructureIntroductions to safeguarding banks, operating accounts, card scheme sponsors and payment system access
PeoplePreparation of directors, the compliance officer and the MLRO for FCA questions and interviews
After authorisationRegulatory returns, safeguarding audit readiness, monitoring and change management

The licence types and their thresholds are set out in the firm's guides to the UK EMI licence and the UK payment institution licence.

Which firms benefit from a specialist partner

Specialist support adds most value where the team has strong commercial or technical experience but has not taken a firm through FCA authorisation before. It is equally common for established financial groups entering the UK, where the FCA expects a UK management presence and a UK-specific governance structure.

  • Founders launching a first regulated product, such as a business account, a remittance service or a card programme.
  • Overseas groups opening a UK entity, which need a UK board, a UK MLRO and a business plan written for the UK market.
  • Authorised firms adding services through a variation of permission, for example an API adding payment initiation or a new payment service.
  • Buyers of a regulated firm, who need a change in control notification approved before completion.
  • Firms responding to supervisory feedback, where the FCA has asked for improvements to safeguarding or financial crime controls.

What the FCA expects from applicants, whoever drafts the application

The FCA is clear on the role of advisers. Its guidance on applying says firms do not have to use one, that many find an adviser or compliance consultant helpful, and that the FCA expects to deal directly with the firm in correspondence and meetings, not with the adviser. For payment and e-money applications, the main contact named on the form must be an individual at the applicant firm.

Ownership of the content

The FCA states that the policies and procedures submitted with a payment or e-money application should not be generic templates. Case officers test whether the documents match the business model, the transaction flows and the customer base described in the business plan. A partner who drafts with the team, rather than for it, produces documents the firm can defend.

Completeness

The FCA returns a submission without assessing it if the correct fee is not paid or the minimum information is missing. Once accepted, a complete application is decided within 3 months and an incomplete one within up to 12 months, under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. Completeness on day one is therefore the single largest influence on the timetable.

Readiness of the people

The FCA may interview individuals such as the MLRO or the chief financial officer to understand their knowledge and experience. Preparation for those conversations is part of the work, not an extra.

Eight criteria for choosing a regulatory consulting partner

The criteria below reflect what the FCA assesses and what a payment business needs to trade. Each can be tested with documents or verifiable facts before an engagement letter is signed.

1. Specialism in payments and e-money

Payment services and e-money have their own legislation, safeguarding rules and reporting regime, separate from investment or insurance regulation. A partner whose recent work is concentrated in APIs, SPIs and EMIs will know the current FCA application forms, the questions case officers ask and how the CASS 15 safeguarding rules apply in practice.

2. Authorisations that can be verified

Advising on an application is not itself a regulated activity, so the adviser will not appear on the FCA Register for that work. The evidence is the clients' own Register entries. Ask for named firms the partner has taken through authorisation, check each one on the FCA Register, and ask to speak to a director at one of them.

3. Clarity on who does the work

Ask for the names and backgrounds of the people who will draft the business plan, the financial forecasts and the policies, and who will attend calls with the FCA case officer. Senior involvement in the scoping and review stages is what gives an application its coherence.

4. Firm-specific drafting and knowledge transfer

Ask how the partner builds the policies: from workshops with the team, from the firm's own transaction data and risk assessment, or from a standard set. The right answer is the first two, with the firm's staff reviewing and owning each document before submission.

5. Access to banking, safeguarding and payment infrastructure

An authorised firm still needs a safeguarding account at a credit institution, an operating account, and access to payment systems such as Faster Payments, SEPA or SWIFT, usually through a sponsoring bank, and to card schemes through a principal member. A partner with working relationships across these providers can run the banking workstream in parallel with the application. Ask the partner to state any commercial relationship with providers it introduces.

6. Realistic timelines and a written scope

A credible partner quotes the FCA's own service standard, explains what moves a case between the 3-month and 12-month windows, and does not promise an outcome, since only the FCA decides. The scope should list every deliverable, the information the firm must supply and the milestones for each.

7. Support after authorisation

Authorisation starts a set of recurring obligations: regulatory returns, the monthly safeguarding return, the annual safeguarding audit, complaints reporting and annual reviews of financial crime controls. A partner that can support the first year of operation keeps the systems built for the application in use.

8. International reach where the plan needs it

UK firms lost EU passporting rights on 31 December 2020. A UK EMI or PI serves EU customers only through a separate entity authorised in an EU member state, so a business with European plans benefits from a partner that can run a UK and an EU application on one timetable.

CriterionEvidence to request
SpecialismList of payment and e-money engagements in the last three years
Track recordNamed client firms, checked on the FCA Register
TeamNames and CVs of the people drafting and attending FCA calls
Drafting methodA sample policy table of contents and the workshop plan
InfrastructureBanks and providers the partner works with, and any commercial ties
TimelineA milestone plan referenced to the FCA service standard
Ongoing supportA first-year compliance calendar
InternationalEU jurisdictions covered and recent authorisations there

Questions to ask in the first meeting

A first meeting should leave the directors with a written view on the licence, the capital and the timetable. These questions establish whether the partner can provide one.

  1. Which licence does our model need, and what would change that answer?
  2. What initial capital and own funds requirement applies, and how is it calculated for our projected volumes?
  3. How will our safeguarding work: segregation in a bank account, an insurance policy or a guarantee?
  4. Which banks and payment providers are realistic for a business with our customer base and geography?
  5. Who on your team will draft each document, and who will speak with the FCA case officer?
  6. What information do you need from us, and by when, to submit a complete application?
  7. What does the first year after authorisation require of our compliance officer and MLRO?
  8. Which firms have you taken through authorisation, and may we speak to one of their directors?

How engagements are usually structured

Engagements are shaped around what the firm already has. A team with an experienced compliance officer may need only a review; a first-time founder usually needs the full application.

EngagementBest suited to
Full applicationNew firms without in-house regulatory experience
Review of a draft applicationFirms with a compliance officer who has drafted most documents
Single workstreamsFirms needing specific items, such as financial forecasts or a wind-down plan
Change in controlBuyers of an authorised firm and their investors
Ongoing compliance supportAuthorised firms building their first-year monitoring and reporting

Whatever the structure, the engagement letter should state the deliverables, the reliance the firm can place on the work, confidentiality terms and how personal data on directors and controllers will be held.

Regulator costs and capital to budget for

Regulator fees and capital apply whichever partner is chosen, and a good partner builds them into the financial forecasts from the first draft. The FCA's application fees were last updated on 13 July 2026.

ApplicationFCA fee
Small payment institution£1,130
Authorised payment institution£2,820 or £5,640, depending on services
Small e-money institution£1,130
Authorised e-money institution£5,640
Variation adding payment or e-money services£1,410 or £565
Firm typeInitial capital
API: money remittance only€20,000
API: payment initiation services€50,000
API: other payment services€125,000
Authorised EMI€350,000

Initial capital is set in euros by the legislation. Ongoing own funds can exceed it as volumes grow. The full budget, including insurance, audit and staffing, is set out in what an FCA PI or EMI licence costs in 2026.

A realistic timeline

The timetable has two parts: preparation, which the firm and its partner control, and assessment, which the FCA controls. Preparation depends on how settled the business model, the team and the capital are; firms with these in place submit sooner.

PhaseTypical duration
FCA allocation of a case officerUp to 20 working days
Statutory decision, complete application3 months
Statutory decision, incomplete applicationUp to 12 months
Planning assumption for EMI and PI6 to 8 months after submission

The planning assumption allows for questions from the case officer and the firm's responses. Banking and safeguarding arrangements run alongside, so the firm can trade soon after the FCA grants authorisation.

What marks out a strong partner

The strongest partners share a small set of habits that a firm can observe during the selection process.

  • They describe what the FCA looks for and how the firm will evidence it, rather than promising approval.
  • They explain why each document is needed and how it connects to the business plan.
  • They name the team, put the scope in writing and keep to a regular update cycle with the board.
  • They are open about commercial relationships with banks and providers they introduce.
  • They plan the safeguarding arrangements against CASS 15, the FCA's safeguarding regime, from the start, since the audit and monthly return apply from the first period after authorisation.

How Buckingham Capital Consulting approaches this work

Buckingham Capital Consulting has worked on payment, e-money and cryptoasset authorisations since 2013. The firm has obtained FCA EMI authorisation for Dzing Finance, Hryze and HFS, FCA API authorisation for Nexpay, Orbital, Oval and Global Send, and Central Bank of Ireland EMI authorisation for Own Solutions, each of which can be checked on the relevant public register.

Each engagement pairs the application with the banking and payment processing workstream.

Frequently asked questions

Do I need a consultant to apply for FCA authorisation?

No. The FCA says firms do not have to use one, though many find an adviser or compliance consultant helpful in preparing applications.

Will the FCA speak to my consultant instead of me?

The FCA expects to deal directly with the applicant in correspondence and meetings. The main contact on a payment or e-money application must be an individual at the firm.

How long does FCA authorisation take for a payment or e-money firm?

The FCA decides complete applications within 3 months and incomplete ones within up to 12 months. Firms commonly plan for 6 to 8 months after submission.

How can I check a consultant's track record?

Ask for the names of firms it has taken through authorisation and look each one up on the FCA Register, then ask to speak to a director at one of them.

Can a consultant guarantee FCA approval?

No. Only the FCA decides an application; a credible adviser explains what the FCA looks for and how the firm will evidence it.

Does the consultant need to be FCA authorised?

Advising a firm on its application is not a regulated activity, so the adviser is not authorised for that work. Its clients' Register entries are the evidence of its experience.

What should a consultant cover after authorisation?

Regulatory returns, the monthly safeguarding return, the annual safeguarding audit under CASS 15, complaints reporting and reviews of financial crime controls.

References

  1. FCA: How to apply for authorisation
  2. FCA: Apply to become an e-money or payment institution
  3. FCA: Application fees
  4. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  5. The Payment Services Regulations 2017
  6. The Electronic Money Regulations 2011
  7. FCA Financial Services Register

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA e-money and payment institution authorisations for firms including Dzing Finance, Hryze, Nexpay and Orbital since 2013, and arranges the safeguarding and operating accounts alongside each application. The firm supports payment and e-money businesses from licence choice through their first year of supervision.

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.