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FCA Variation of Permission Application 2026: Adding or Changing Regulated Activities

Published 2 February 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a variation of permission is
  2. When a firm needs a variation
  3. What a variation costs
  4. How long a variation takes
  5. What the FCA assesses
  6. Payment and e-money firms: what changes
  7. What goes into the application
  8. The process step by step
  9. After the variation is granted
  10. Frequently asked questions
Key takeaways
  • An authorised firm must have FCA approval before it starts any new regulated activity, product or client type outside its current permission; starting early is a breach of FCA rules.
  • For FSMA firms the fee is £560 (Category 2) when the firm stays in the same fee-block, 50% of the new-firm fee when it moves into a new fee-block, and nil when it only removes activities.
  • Payment and e-money firms pay 50% of a pricing category: £1,410 for an authorised payment institution adding services, £2,820 for an authorised e-money institution adding services and £565 for a small payment institution or small e-money institution.
  • The law allows the FCA 6 months for a complete FSMA variation and 12 months for an incomplete one; its 2026 targets are 4 months, or 3 months for variations close to the existing business.
  • The FCA's median time to decide a payment or e-money variation in Q1 2026/27 was 164 days, about 5.4 months, so launch plans should allow for a full assessment.
  • A small payment institution or small e-money institution cannot vary into an authorised firm: it applies for full authorisation instead.

What a variation of permission is

A variation of permission (VoP) is the FCA's approval to change what an authorised firm is allowed to do. Every FSMA firm holds a Part 4A permission that lists its regulated activities, the investments and client types they cover, and any limitations or requirements attached. The scope shown on the Financial Services Register should match what the firm actually does.

Payment and e-money institutions are authorised under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011 rather than FSMA. Their equivalent is a variation of authorisation or registration. The process runs through the same FCA system, Connect, but the fees, capital and statutory periods follow those regulations.

The four types of variation

  • Adding activities: starting a new regulated activity or business line.
  • Removing activities: taking out an activity the firm no longer carries on.
  • Changing scope: adding or restricting the products, investment types or client types covered, for example moving from professional clients to retail customers.
  • Changing limitations or requirements: adding, varying or removing conditions on the permission, such as a requirement not to hold client money.

When a firm needs a variation

The test is simple: does the planned activity fall within the firm's current permission? If it does not, the firm needs approval before it starts. The FCA states that beginning the activity before approval breaches its rules and can lead to enforcement action. Firms that want to add accepting deposits or effecting or carrying out contracts of insurance apply to the Prudential Regulation Authority instead.

FirmCommon reasons to apply
Authorised payment institutionAdding payment services, such as moving from money remittance to payment accounts, card issuing or acquiring, or adding payment initiation or account information services
Authorised e-money institutionAdding payment services unrelated to issuing e-money, or adding payment initiation and account information services
Small payment institution or small e-money institutionAdding payment services within the small-firm limits
Investment firmAdding dealing, arranging, managing or safeguarding and administering investments; taking on retail clients; holding client money
Consumer credit firmMoving from limited to full permission, or adding lending, debt collection or debt administration
Insurance or mortgage intermediaryAdding advising, arranging or lending activities, or new product types

When a variation is not the route

Some changes need a different application. A small payment institution or small e-money institution that grows beyond the small-firm limits, or wants the wider rights of an authorised firm, applies for full authorisation; it cannot vary into one. A new owner taking 10% or more of the firm needs change of control approval. A new senior manager needs a separate senior manager application, which can run alongside the variation.

What a variation costs

The FCA sets the fee by reference to its pricing categories, published on its variation of permission fees page and in Annexes 8 and 10 of the FEES 3 chapter of its Handbook. The fee is paid on Connect before assessment starts and is not refunded. The figures below use the 2026/27 categories (Category 2 £560, Category 3 £1,130, Category 4 £2,820, Category 5 £5,640).

FSMA firms

VariationFee
Firm stays in the same fee-block£560 (Category 2)
Firm moves into one new fee-block50% of the new-firm application fee for that fee-block
Firm moves into more than one new fee-blockThe highest of the relevant fees
Firm keeps or reduces its scopeNo fee

Payment and e-money firms

VariationFee
Authorised payment institution adding payment services£1,410 (50% of Category 4)
Authorised e-money institution adding services£2,820 (50% of Category 5)
Authorised e-money institution adding payment initiation or account information services£1,410 (50% of Category 4)
Small payment institution adding payment services£565 (50% of Category 3)
Small e-money institution varying its registration£565 (50% of Category 3)
Removing services onlyNo fee

The payment institution fees apply regardless of how many agents the firm has. A variation can also change the firm's annual periodic fees, because those depend on the fee-blocks it sits in, so the new annual cost belongs in the business case.

How long a variation takes

FSMA gives the FCA 6 months to decide a complete application and 12 months from receipt to decide an incomplete one. Since January 2026 the FCA has measured itself against shorter targets, and it publishes the results each quarter in its authorisations service metrics.

ApplicationCompleteIncomplete
Statutory maximum (FSMA)6 months12 months
FCA target: variation of permission4 months10 months
FCA target: variation close to the existing business3 months6 months
FCA target: payment and e-money variations3 months10 months

In Q1 2026/27 the FCA's median time to determine a variation close to the existing business model was 44 days. For payment and e-money variations the median was 164 days, about 5.4 months, because adding services usually changes the firm's capital, safeguarding and financial crime controls. A variation that is well documented at the outset, with the systems already built, sits at the shorter end of these ranges.

What the FCA assesses

The FCA treats a variation as a test of whether the firm will still meet the threshold conditions once it carries on the new activity. The case officer looks at the change itself and at the firm's record since authorisation.

  • Business model: why the firm wants the new activity, who the customers are and how it fits the existing business.
  • Resources: capital, liquidity, people and systems sized for the expanded business.
  • Governance: who is accountable for the new activity, and how the board will oversee it.
  • Controls: compliance monitoring, financial crime controls, safeguarding and operational resilience extended to the new activity.
  • Customer outcomes: how the new product meets the Consumer Duty for retail customers.
  • Supervisory record: timely regulatory returns, an open relationship with the FCA and any open issues resolved.

A firm with a clean reporting record and a variation close to its current business gives the FCA the least to examine, which is reflected in the shorter target for adjacent variations.

Payment and e-money firms: what changes

For payment and e-money institutions a variation usually changes the prudential position as well as the permission.

Authorised payment institutions adding services

Initial capital rises with the services held: €20,000 for money remittance only, €50,000 for payment initiation services and €125,000 for other payment services, set in euros by the Payment Services Regulations 2017. The FCA expects to see the higher capital in place, the own funds calculation updated, safeguarding extended to the new flows and transaction monitoring adapted to the new financial crime risks.

Authorised e-money institutions adding payment services

An e-money institution holds €350,000 initial capital. Where it adds payment services unrelated to issuing e-money, it calculates own funds for both activities, safeguards both sets of funds and shows how its governance covers each. The application should set out the combined capital and safeguarding position.

Worked example: a remittance firm adding payment accounts

An authorised payment institution licensed for money remittance only holds €20,000 initial capital. To offer payment accounts and cards it applies to add the relevant payment services, and the fee is £1,410. The application shows initial capital of at least €125,000 in place, a revised own funds calculation, safeguarding extended to account balances, transaction monitoring updated for account-based activity and a revised wind-down plan. Once approved, its monthly safeguarding return and annual safeguarding audit under CASS 15 cover the new flows from the first day.

Small firms

A small payment institution can add services within the small-firm conditions, including the average monthly payment transactions limit of €3 million. Above that, or to gain the wider rights of an authorised firm, it applies for authorisation; the firm's UK payment institution licence guide covers that application.

What goes into the application

A variation is made on Connect, through the Part 4A variation forms for FSMA firms or the payment services and e-money variation forms. The case officer may ask for more. A complete application normally includes:

  • An updated regulatory business plan describing the new activity, customers, distribution and revenue.
  • Revised financial forecasts, normally for three years, with the capital and liquidity calculations and a stress scenario.
  • Updated policies and procedures for compliance, anti-money laundering, risk, complaints and, where relevant, safeguarding and client money.
  • Governance changes: board and committee arrangements, the reporting lines of control functions and, for SM&CR firms, updated Statements of Responsibilities and responsibilities map.
  • Details of new outsourcing, systems and third parties that the new activity relies on.
  • An updated wind-down plan reflecting the larger business.

Systems descriptions need specifics: how transaction monitoring scenarios cover the new product, how safeguarding reconciliations include the new flows and which reports go to the board. Generic statements prompt follow-up questions that extend the assessment.

The process step by step

  1. Confirm the gap. Map the new product against the current permission on the Register and the Perimeter Guidance manual, and decide whether a variation, a new authorisation or another notification is needed.
  2. Build the change. Put the capital, people, systems and contracts in place, and have the board approve the plan.
  3. Prepare and submit. Complete the Connect forms, attach the documents, and pay the fee. The FCA confirms receipt by email.
  4. Work with the case officer. Answer questions promptly and fully; arrange senior manager applications in parallel where needed.
  5. Receive the decision. The Register is updated and the firm may start the new activity from the date the FCA confirms.

If the FCA proposes to refuse a variation, or to grant it on terms the firm has not agreed, it gives a warning notice and explains how to respond. A firm can withdraw an application before a decision by writing to its case officer. The firm's guide to applying for FCA authorisation explains the decision process in full.

After the variation is granted

The new permission brings new obligations from the first day. Regulatory returns may change in content and frequency, so reporting systems need to produce the new data from the date of approval. Annual fees can rise where the firm moves into new fee-blocks, and capital and safeguarding calculations must reflect the expanded business at once.

The FCA expects permissions to be used. It can cancel a permission that has not been used for 12 months, so a firm that adds an activity should plan to start it within that period. Senior managers taking on the new activity need their Statements of Responsibilities updated, and the firm's SM&CR guide covers what changes when responsibilities move.

Frequently asked questions

How much does an FCA variation of permission cost?

For FSMA firms it is £560 in the same fee-block, or 50% of the new-firm fee for a new fee-block. An authorised payment institution adding services pays £1,410, an authorised e-money institution adding services pays £2,820, and small payment and e-money institutions pay £565.

How long does an FCA variation of permission take?

The FCA targets 4 months for a complete application, 3 months for variations close to the existing business, and 3 months for payment and e-money firms. The statutory maximum is 6 months for a complete FSMA application and 12 months for an incomplete one.

Can I start the new activity while the variation is being assessed?

No. The FCA states that carrying on the activity before approval breaches its rules and can lead to enforcement action.

Is there a fee to remove permissions?

No. There is no application fee where a firm keeps or reduces its scope, or where a payment or e-money firm only removes services.

Can a small payment institution vary into an authorised payment institution?

No. A small payment institution applies for full authorisation under the Payment Services Regulations 2017 to become an authorised payment institution.

Do I need a new senior manager for the new activity?

Only if the variation creates a new senior management function or moves responsibilities to someone not yet approved. That person's application can run alongside the variation.

Can the FCA remove a permission I am not using?

Yes. The FCA can cancel a permission that has not been used for 12 months.

References

  1. FCA: Variation of permission
  2. FCA: Variation of permission application fees
  3. FCA: Application fees for EMIs and payment institutions
  4. FCA Handbook: FEES 3 Annex 8 (payment services application fees)
  5. FCA Handbook: FEES 3 Annex 10 (e-money application fees)
  6. FCA: Authorisations operating service metrics 2026/27 Q1
  7. Financial Services and Markets Act 2000, Part 4A (legislation.gov.uk)

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations and variations since 2013, including a variation of permission for Moneliq and payment and e-money licences for Nexpay, Orbital, Global Send, Dzing Finance and Hryze. The firm confirms whether a variation is needed, prepares the business case, forecasts, capital calculations and policies, and manages the FCA's questions through to approval.

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.