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Financial Conduct Authority

UK FCA investment manager authorisation pack

A practical evidence pack map for FCA investment manager authorisation, permissions, SM&CR, client assets, outsourcing, regulatory business plan, financial forecasts, and asset management good-practice issues.

Route focus

A UK investment manager application needs to prove the permissions and investment types, whether the business is individual or collective portfolio management, and whether the firm is ready, willing, and organised to operate with credible governance, prudential, CASS, outsourcing, conflicts, and redress arrangements.

Who this helps

  • - UK discretionary investment managers preparing FCA authorisation
  • - Fund managers and separate-account managers choosing UK MiFID, AIFMD, UCITS, or combined analysis
  • - Wealth, portfolio, or private markets managers adding client money, custody, or outsourcing complexity
  • - SMF candidates and compliance teams preparing Form A and senior accountability evidence

Licence scope

  • - Identify whether the model is individual portfolio management, collective portfolio management, AIFM/UCITS-related, or a hybrid.
  • - Map permissions such as managing investments, advising on investments, arranging, dealing as agent, agreeing to carry on regulated activities, and client money/custody permissions where relevant.
  • - Check client type, investment type, MiFID/MIFIDPRU status, CASS position, financial promotions, and appointed representative or outsourcing assumptions.
  • - Use the FCA asset management good/poor practice page as a live quality-control checklist, especially for completeness, location, outsourcing, business model, conflicts, client status, and redress.

Pre-draft questions

  • - Which permissions are needed for each part of the client journey?
  • - Will the firm hold or control client money or client assets, or arrange safeguarding and administration?
  • - Where are mind and management, portfolio decisions, investment committee meetings, compliance, and outsourced functions actually located?
  • - Which SMFs, certification staff, Conduct Rules populations, compliance owner, MLRO, CASS owner, and finance owner are needed?
  • - Do the regulatory business plan and three-year forecasts prove the same model as the permissions requested?

Evidence pack

Regulatory business plan

  • - Permission and investment-type matrix, client type, products, investment strategy, revenue model, launch restrictions, and distribution plan.
  • - Individual versus collective portfolio management analysis, AIFM/UCITS/MiFID status, MIFIDPRU/PMR or other prudential basis, and CASS position.
  • - Three-year financial forecasts, capital calculations, wind-down plan, fee assumptions, and stress case.

Systems and controls

  • - SM&CR map, statements of responsibility, compliance monitoring plan, AML/financial crime controls, conflicts, personal account dealing, best execution, CASS, complaints, and financial promotions.
  • - Outsourcing register, due diligence, service levels, exit plan, management information, technology controls, business continuity, and operational resilience notes.
  • - Client status evidence, redress/FSCS/FOS analysis where relevant, suitability and disclosure controls, and marketing approval workflow.

FCA application support

  • - Connect application evidence, forms, ownership/controller information, fees, regulatory references, criminal background checks where relevant, and case-officer response log.
  • - Good/poor practice self-check against current FCA asset management application observations.
  • - Register, RegData, annual attestation, directory-person, reporting, and post-authorisation task owner list.

People and governance

  • - SMF applications should be ready on day 1 where they are part of the authorisation route.
  • - Senior managers need a clear map of who owns portfolio management, compliance, MLRO, finance, CASS, outsourcing, complaints, and wind-down.
  • - Certification and Conduct Rules processes should be documented even where people are not individually approved.
  • - If an outsourced provider or group affiliate is central, the applicant still needs to show oversight and accountability.

Forms and submission

  • - Prepare the FCA Connect application with regulatory business plan, financial forecast, permissions map, supporting forms, and SMF materials.
  • - Use FCA investment manager guidance, how-to-apply guidance, SMF guidance, and current asset management application observations as a pre-submission quality gate.
  • - After approval, check the Financial Services Register, RegData, annual attestation, fees, and ongoing notification tasks.

Timeline risks

  • - Incomplete or unclear applications materially delay determination.
  • - Common issues include office location/mind and management, outsourcing accountability, business models exposing clients to risk, conflicts, client status, and redress assumptions.
  • - CASS, prudential, SM&CR, wind-down, and forecast inconsistencies often create follow-up rounds.

Questions to ask advisers

  • - Which permissions are genuinely needed, and which can be limited for launch?
  • - Is the model UK MiFID, AIFMD, UCITS, or a combined route?
  • - Does the CASS position match client money, custody, mandates, fees, and platform flows?
  • - What FCA good/poor practice risks are visible before submission?

Common mistakes

  • - Copying a generic compliance manual without proving the actual investment workflow.
  • - Underestimating outsourcing accountability because a group affiliate performs key functions.
  • - Leaving SMF, certification, and Conduct Rules evidence until after forms are drafted.
  • - Requesting permissions broader than the capital, systems, people, and forecasts can support.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.