FCA AUTHORISATION
Get Authorised With Confidence
To get FCA authorised is a significant milestone but the process is complex, and missteps can delay your plans.
Adempi's team has helped hundreds of firms to secure their FCA licence. We provide expert support you identify and secure the FCA permissions you need.
Whether you’re starting up, spinning out or taking the next step, we’ll guide you through the FCA approval process so you know what's required, why and how to put your best foot forward.
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We support firms across the full authorisation lifecycle—from preparing and submitting initial applications to hamdling FCA questions and interviews, and taking those final steps to confirm readiness.
For appointed representatives wanting to become directly authorised we also help firms transition out of the regulatory hosting models they are using.
Clients usually continuo using us once they obtain FCA approval, using one of our ongoing supprt services.
Authorisations are just one of Specifically, we can support financial services firms with the following FCA applications:
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FCA authorisations
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Variation of permissions
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Change in control processes
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Appointed representative arrangements
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Regulatory hosting transitions
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FREQUENTLY ASKED QUESTIONS
Do I need FCA authorisation? If you conduct regulated activities from the UK by way of business and no exclusion or exemption applies, you will need authorisation before you can begin trading. Conducting regulated activity without authorisation is a criminal offence under section 23 FSMA, and client agreements your firm enters into while in breach of this are unenforceable against the customer. The most overlooked trigger that we see is businesses that make introductions. Bringing together two other parties in connection with finance is often a regulated activity. For example: in consumer credit, the activity would be credit broking for investments, arranging (bringing about) deals in investments and/or making arrangements with a view to transactions in investments for mortgages it would be arranging regulated mortgage contracts for insurance, arranging deals in contracts of insurance Many firms don't realise they need authorisation, an exclusion, or appointed representative cover before they can make introductions. There is no one test for "by way of business": it varies by activity but how often you undertake the activity and whether you are paid for it normally forms part of the assessment but you can find the tests in the FCA’s PERG sourcebook. Adempi can help you determine whether your business falls within the FCA's regulatory perimeter, identify the permissions you require and guide you through the authorisation process.
How do I know which FCA permissions I need? Identifying the permissions to apply for in your authorisation application means mapping each thing you plan to do against the Regulated Activities Order, then working through the factors that modify the picture, such as whether you'll: deal with retail or professional clients hold client money or custody assets need any additional permissions to support the core activity Applying for the wrong permissions can delay your application or result in unnecessary regulatory obligations. While too few permissions can leave you unable to act, or needing to rely on third parties, there are also long-term consequences to having more permissions than you need. Many businesses start by thinking that the extra flexibility for the business will be beneficial but underestimate the cost that is attached to having this. Permissions drive your prudential category which drives a myriad of risk and capital requirements so flexibility could be costing you tens, or hundreds, of thousands of pounds in capital that you can’t dip into. Permissions also drive the volume of policies and procedures that apply to your business and in some cases increase the standards that need to be contained within them. We know how to balance the pace of firms’ ambitions with the real-world consequences. The answer looks different for each client. We assess your business model, understand your goals and identify the permissions that best reflect your growth plan, helping to ensure the application is accurate from the outset.
How do I apply for FCA authorisation? You apply through the FCA's Connect portal. After answering a number of questions about your firm type and activities, you will reach a page from which you can download core forms that the FCA wants you to complete and reupload, alongside supporting documentation that you create. Make sure to answer the Connect questions correctly. We come across firms who have made a mistake when answering the questions and are devastated to have wasted precious time and money filling in and submitting the wrong forms only for the FCA to reject their original paperwork. After downloading your forms, which will say what supporting documents you need and what they should contain, we recommend that the next step is preparing your regulatory business plan and your financial projections. These two documents provide the content needed by many of your FCA forms so they are the cornerstone of your application. From there, complete the FCA forms themselves. These will cover a range of themes including business model, governance arrangements, past trading history, key personnel, volumes of business and summaries of compliance documentation. Our team’s expertise in knowing what the FCA expects feeds directly through to the templates we use, how we present your firm when we’re drafting, and the advice we provide when reviewing documents that your team has held the pen on. How long should you be prepared for all the preparation to take? We think 8 weeks is realistic. It could be half that time with a fair wind, but more often we see firms underestimate the internal resource they need to turn around reviews of drafts or requests for information. We can move quickly but the other things happening in your business may dictate how available your team is to prioritise the application. Our top tip? One sentence in your business plan can drive twenty answers across the forms, so a late change of mind means enormous rework — get it right in the core document and extrapolate from there.
What documents do I need for an FCA authorisation application? The FCA expects a core set of supporting documents with every application. Though the exact list depends on the permissions you're seeking, the FCA will typically expect to see documents such as: A regulatory business plan Financial forecasts Governance and organisational structure Compliance monitoring arrangements Anti-money laundering policies (where applicable) Complaints procedures Risk management framework IT infrastructure Details of senior management and key individuals A wind-down plan If you’re going it alone, take our three top tips with you: Your financials need to tie back to the business plan so split out income generated from different activities. Make sure your expenses tie back to the overheads you’ve described and don’t exaggerate what you expect to make – this is not a pitch for investment, the FCA is looking for realism. Get management responsibilities clear before you start drafting. Even if you’re a small firm, the FCA expects you to divide responsibilities clearly and this will apply to everything from the line management responsibilities being clear in your staff structure chart, to showing meaningful delineation of what areas of the business managers are responsible for in their statements of responsibilities. The wind-down plan often gets missed but increasingly the FCA expects to see it at application stage. It sets out how you would close down in an orderly way without harming clients or the market. If you want to look credible you should tailor it to your business rather than using a generic template. The FCA will expect it to be grounded in your actual financial forecasts and cash position. The FCA publishes helpful guidance on preparing a wind-down plan, including a link to its Wind-Down Planning Guide. Work with us and we'll advise you on what documentation is required for your specific application and help ensure it not only meets the FCA's expectations but is also proportionate and fitting for your business model and scale.
How long does FCA authorisation take? From January 2026, the FCA has faster authorisation targets. The time to determine applications was shortened to 4 months (from 6) when the application is deemed to be complete, and 10 months (from 12) for incomplete applications. Since then we've seen a faster process for the clients we’ve supported with authorisation. They now usually hear from their case officer within 10 business days and are interviewed, or asked meaningful questions, within a month. The overall timeframe for your firm’s application will depend on how risky the FCA deems your business to be, how complex your ownership structure is, how strong the team are (e.g. blend of skills, previous experience) and what permissions you are applying for. Applications that are well prepared, supported by clear documentation and submitted with the correct permissions identified from the outset generally attract a faster processing time from the FCA and are more likely to be deemed complete. We can tell you realistically what to expect for a firm with your structure, size and proposed activities.
Will I be interviewed by the FCA as part of the authorisation process? In applications we've supported since January 2026, we’re seeing increased use of online meetings by the FCA as a first step in their review of an application for authorisation. The FCA won't usually call it an interview. In our experience the invitation arrives as a request for a Teams call or online meeting. Treat it as an interview anyway: it's an opportunity for the FCA to test whether your team can speak to its own business plan, and to identify any concerns about the calibre of the people who will be running the firm. Expect the meeting to last about an hour, and expect your key senior managers to be invited. This is not something your compliance officer will be handling on their own. There is not usually an agenda provided; rather it is framed more as a conversation around the firm’s business model and resources or on specific points in the documents you've submitted. If the meeting goes well, it could mean a quick determination of your application, but if the FCA sees a senior manager who can’t speak to compliance or the detail of the application submitted, this at best will trigger more questions and a longer process. It is therefore important that the people attending are prepared. We offer pre-interview support so that you can meet with the regulator confident that you will be able to present your business well. This includes advising you on what themes might arise, based on your application and sector, and how your answers might land.
What are the most common reasons FCA applications are delayed? Most delays come from the same place: the FCA needs to ask you something before it can move on. Every round of questions adds time, so the fewer you trigger, the faster the process. If the FCA treats your application as complete, it has four months to determine your application, rather than ten. Whether your application is complete is the FCA's assessment to make, but the things that most often prompt further questions are within your control: inconsistencies between the business plan and the financial forecasts governance arrangements that don't match the size or shape of the firm permissions applied for that don't line up with the business model described or can’t be supported by the firm’s resources insufficient experience at senior management level providing answers and documents that are generic rather than specific to your firm In our experience the pattern is rarely a missing document. It is more often that something in the pack doesn't quite hang together with something else, and the FCA asks about it. When the FCA does come back, response times are short. Across the applications we supported in 2026 response times were 7 to 14 days. Firms that have held back some resource for this stage tend to turn responses around more effectively. We help firms anticipate the questions before submission, reducing the volume and depth of questions and we stay with you through the query stage so the responses go back quickly and consistently with what you set out in your application.
What happens if the FCA refuses or challenges my application? Outright refusals are rare. Far more common is that the FCA raises concerns during its review, and how you respond determines what happens next. Should you be faced with a concerned regulator, you have three main routes: address the concerns to the FCA’s satisfaction and continue choose to withdraw the application before the adverse decision is made let it proceed to a decision so that you can then contest it If the FCA is not “minded to approve” your application, it will usually tell you before it decides. In practice that often means a conversation with your case officer first, and the case officer may encourage you to withdraw before any formal notice process begins. Withdrawing is not the same as being refused. A withdrawn application ends the process without a refusal on your record. You will need to disclose it in future applications and the FCA is likely to look back at past concerns when you resubmit. However, for many this is a preferable outcome. A refusal concludes with a Final Notice, and the FCA has discretion to publish information about it — sometimes naming the firm, sometimes anonymised. This is why firms facing serious FCA concerns often choose or agree to withdraw their application. Then they fix the underlying issue and reapply, rather than pressing for a decision they are unlikely to win. There are a lot of things to consider. Withdrawing costs you the application fee and the time already invested, and you start again. Pressing on risks a refusal that follows the firm and its senior managers. The right answer depends on whether the FCA's concern is something you can actually fix — a documentation gap usually is; a fundamental problem with the business model, the funding, or the people usually isn't. Hopefully, you don’t get to this stage. We work hard to make sure the clients we work with are ready for authorisation before we begin preparing an application and we know how to spot likely issues along the way and help you to address them before it reaches this stage that refusal is being discussed.
Do I need ongoing compliance support after FCA authorisation? Yes. Most firms find that some kind of compliance support after authorisation is useful. The first priorities for a newly authorised firm are compliance training and ensuring that their new compliance framework is properly embedded so these are often the first things we are asked to help with. Across the rest of the first year, needs change. For some firms having a sounding board or second pair of eyes is the priority, so that their team can take on new tasks like reporting to the FCA and undertaking monitoring with confidence that they are doing things properly. For other firms, having practical operational support to take on the burden of some of the new compliance tasks is the real value. For all the firms we work with, the ability to ask the tough questions of someone else when tricky things arise matters. These questions can be triggered by external causes like financial crime and cyber events, or internal changes, like working through how to manage a business change once regulated. By the time you are authorised, the consultant who helped you through that process will know your business model inside out, so there is no better place to go for quick, tailored responses to questions once you are regulated. Our ongoing support services can be tailored to exactly what your firm needs. We have retainers and framework arrangements that flex to the volume, style and type of help firms need both at the outset and as they scale. Even our fully established clients make the most of having a service that can adapt to changing needs.
Can I change my FCA permissions later? Yes. As a regulated business you will be regularly reviewing whether you need more or fewer permissions and, if you do, you will apply for a Variation of Permission (VoP) through the FCA’s Connect system. Some firms worry it will be like going through the authorisation twice but VoPs tend to be more straightforward both for preparation and in the interaction with the FCA. The FCA has set itself a three-month target to process VoP applications that are related to the firm’s original business model. Ideally, you don’t want to ask for extra permissions too soon after authorisation, as the FCA may question whether in your application you were fully transparent about your business’ needs. However, it is also true that the needs of businesses develop over time as plans develop or accelerate. There is a cost associated when you add permissions, but not if you are removing them. If the permissions you add move you into a new fee block, the cost is half of what the authorisation application would have been. Otherwise, it is a flat fee which varies but is currently under £600 in all cases. For example, an investment intermediary firm adding asset management would enter the Category 6 fee-block for the first time, so would pay 50% of the £11,260 applying to asset management authorisations, which is £5,630. We can help assess whether your existing permissions remain appropriate and manage the application process to ensure your regulatory permissions continue to reflect your business activities.
How much does FCA authorisation cost? There are two costs, the FCA's fee and the cost of getting the application prepared. The FCA’s fee is a non-refundable application fee to be paid at the point of submission. As you can see from their website, FCA application fees vary depending on the complexity. The fees in the 2026/27 financial year range from £560 for limited permission consumer credit firms up to £225,170 for a Recognised Investment Exchange. In this period, most asset managers will pay £11,260, which is also the most that a full permission consumer credit firm will pay. Most Authorised Payment Institutions or Authorised E-money Institutions will pay £5,640. Most intermediaries like financial advisers and corporate finance firms will pay £2,820. The cost of compliance support is also impacted by this complexity because the volume of paperwork and types of risk scrutinised by the FCA increase in line accordingly. We can give you a precise figure when we learn more about your business but to have your application fully prepared and your policies and procedures created, it is usually worth budgeting £17,000 to £25,000 plus VAT for a straightforward application like corporate finance or investment intermediation, and £30,000 to £45,000 for a moderately complex application like an asset manager or API/AEMI application. For more complex applications we'll quote once we understand the model. We also offer different levels of support to firms but this tends to be best for teams that have the skills and availability to do much of the work themselves. As this is not for everyone, the cost saving is not factored into the fee ranges listed above but do ask us about it if that sounds right for your firm. The cost of FCA authorisation isn’t cheap, but appointing great consultants adds real value. Professional support helps reduce delays, minimise requests for additional information and improve the quality of the submission. We're happy to discuss your business and provide an indication of the level of support that may be required.