Corporate requirements
- - UK entity or branch model with permissions, investment types, and client types mapped
- - Regulatory business plan, financial forecasts, capital/prudential analysis, and systems and controls
- - SM&CR mapping, governance, compliance monitoring, AML, complaints, CASS, outsourcing, and wind-down planning
- - Evidence that the firm is ready, willing, and organised at application stage
Application journey
- 1. Map activities and investment types to the FCA permissions needed.
- 2. Select the correct firm-type guidance, including investment manager, adviser, platform, or wholesale market pages.
- 3. Prepare regulatory business plan, 3-year forecasts, governance, SM&CR, policies, prudential analysis, and CASS position.
- 4. Submit through FCA Connect and respond to case officer questions.
- 5. After authorisation, maintain register accuracy, reporting, RegData, annual attestations, and approved-person changes.
Documents and controls
- - People and competence: Shows that named individuals can perform or supervise the regulated work.
- - Ownership and controllers: Explains who owns, controls, funds, and benefits from the applicant.
- - Governance and accountability: Allocates decision rights, oversight, senior responsibility, committees, and escalation.
- - Capital and financial resources: Shows runway, prudential planning, and resource adequacy for the proposed permissions.
- - AML/CFT and financial crime: Shows customer due diligence, sanctions, monitoring, suspicious activity, and escalation controls.
- - Compliance framework: Turns rules into owned, scheduled, evidenced operating controls.
- - Custody and client assets: Explains whether client assets are held, controlled, safeguarded, deducted from, or avoided.
- - Outsourcing and vendors: Shows that outsourced work is selected, supervised, escalated, and replaceable.
- - Cyber and technology controls: Shows platform resilience, access control, business continuity, incident response, and data protection.
- - Complaints and conduct: Shows conduct risk ownership, customer handling, and escalation for complaints or disputes.
- - Regulatory reporting: Shows that recurring reports, filings, amendments, attestations, and register changes are owned.
- - Financial forecasts: Connects business plan, revenue assumptions, costs, capital, and runway to the applicant entity.
- - Wind-down and exit planning: Shows how clients, assets, records, complaints, and obligations would be handled if the business stops.
Capital and timeline
Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model.
Timeline estimate: FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months.
Common bottlenecks
- - Permissions requested do not match the actual operating model
- - Financial forecasts are inconsistent with the applicant legal entity or prudential category
- - Weak governance, SM&CR ownership, or compliance monitoring
- - CASS, outsourcing, wind-down, and technology controls are not tailored to the firm