UK FCA financial adviser authorisation pack

Route focus

A UK financial adviser application should prove the advice journey, products, client types, permissions, competence route, SMF ownership, Consumer Duty controls, financial resources, and whether the firm is MiFID, MiFID-exempt, appointed-representative-led, or directly authorised.

Who this helps

• - UK financial adviser founders preparing direct FCA authorisation
• - Sole advisers and small advice firms moving from appointed representative status to direct authorisation
• - Wealth, pension, insurance, mortgage, or investment advice firms checking whether permissions and forms match their client journey
• - Compliance teams preparing SMF16, SMF17, adviser qualification, Consumer Duty, and redress-liability evidence

Licence scope

• - Map personal recommendations, arranging, advising on investments, advising on pension transfers or opt-outs where relevant, insurance or home finance permissions, structured deposits, and investment-only versus combined product scope.
• - Separate direct authorisation from appointed representative, introducer, distributor, investment manager, stockbroking, platform, and wholesale-broker routes before selecting forms.
• - Decide whether the firm is MiFID, MiFID-exempt, non-MiFID, or mixed, and whether it needs MiFID forms, non-MiFID forms, retail-firm supplements, or restrictions/limitations at launch.
• - Tie individual adviser competence to FCA training and competence, TC App 4 appropriate qualification tables, supervision, certification, Conduct Rules, and the firm's own advice file controls.

Pre-draft questions

• - Where does the customer receive a personal recommendation, advice service description, suitability report, arrangement, ongoing service, or product recommendation?
• - Which products are in scope: retail investment products, securities, funds, pensions, structured deposits, insurance, home finance, or a narrower launch set?
• - Which SMFs, advisers, certification staff, compliance owner, MLRO, complaints owner, Consumer Duty owner, financial controller, and outsourced providers are needed?
• - Does the firm have any prior client bank, past advice, phoenixing, redress liability, deed poll, complaint, or connected-firm issue that the FCA will expect to understand?
• - Do the Connect forms, regulatory business plan, adviser qualifications, three-year financial forecasts, Consumer Duty evidence, website, client agreements, and Financial Services Register expectations describe the same advice model?

Evidence pack

People and governance

• - The application should make competence concrete: which adviser can advise on which products, under whose supervision, and with which qualification or certification evidence.
• - SMF16 and SMF17 files should show capacity and business-model understanding, not only experience or consultant support.
• - A sole-adviser or founder-led firm still needs governance, complaints, financial crime, compliance monitoring, and Consumer Duty evidence that works when the key adviser is busy or absent.
• - Where the firm is leaving an appointed representative model or acquiring a client bank, document past liability, redress, ongoing service, complaint, and customer-outcome risks before submission.

Forms and submission

• - Use FCA Connect and the consumer-investments firm page to choose the MiFID or non-MiFID application route, required forms, supplements, controller forms, individuals forms, IT questionnaire, checklist, and declaration.
• - Prepare the regulatory business plan, financial adviser financial-data template, forecasts, SMF materials, Consumer Duty evidence, and training/competence file before submitting.
• - Use the FCA application-fee page to confirm the expected category, then reconcile fees, forms, permissions, limitations, and financial resources before final submission.
• - After approval, verify the firm, permissions, approved persons, directory persons, requirements, and warnings context on the Financial Services Register before launch communications.

Timeline risks

• - The FCA authorisation page states complete FSMA applications are usually assessed within 6 months, while incomplete applications can take up to 12 months.
• - Advice applications slow down when the firm cannot explain its permissions, product scope, adviser competence, Consumer Duty evidence, financial forecasts, redress liability, or SMF16/SMF17 capacity.
• - Generic business plans, draft documents, late financial templates, missing adviser qualifications, weak ongoing-service evidence, or unsupported consultant-written responses can create avoidable follow-up.
• - Substantive model changes during review may signal that the firm was not ready, willing, and organised when it submitted.

Questions to ask advisers

• - Is this direct FCA authorisation, appointed representative status, introducer activity, investment management, stockbroking, or a combined route?
• - Which permissions and product supplements match the first 12 to 24 months of advice activity?
• - Which advisers need appropriate qualifications, certification, supervision, directory-person data, or restrictions before launch?
• - How will the firm prove Consumer Duty outcomes, ongoing service delivery, suitability, adviser charging, complaints, redress, and financial resilience?

Common mistakes

• - Treating a financial adviser application as only a Connect form rather than proof of a ready, willing, and organised advice business.
• - Assuming adviser qualifications solve firm authorisation, SM&CR, Consumer Duty, financial forecasts, redress, and controls.
• - Using a generic regulatory business plan that does not explain the real advice journey, product panel, fees, target market, or ongoing service.
• - Ignoring past client-bank, appointed-representative, complaint, or redress liability issues until the FCA asks.

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.