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Financial Conduct Authority

UK FCA investment platform and CASS authorisation pack

A practical evidence pack map for UK investment platform applicants, including platform permissions, client money and safe custody asset facts, CASS classification, SMF18 ownership, Consumer Duty, technology controls, and FCA Connect evidence.

Route focus

An investment platform application should prove exactly how the platform markets, onboards, routes orders, holds or controls client money or safe custody assets, charges fees, uses custodians or brokers, and protects retail or professional clients from day 1.

Who this helps

  • - UK investment platforms preparing FCA consumer-investments authorisation
  • - Wealthtech, adviser-platform, direct-to-consumer, SIPP-linked, and fund supermarket models mapping platform permissions
  • - Founders and compliance teams checking whether CASS, SMF18, custody, order routing, or client money changes the route
  • - Existing authorised firms adding platform features, custody flows, client assets, or direct retail access

Licence scope

  • - Map the platform journey from marketing, client onboarding, account opening, client classification, advice or non-advice positioning, order routing, execution, settlement, custody, client money, fees, complaints, and exit.
  • - Separate investment platform authorisation from financial adviser, wealth/stockbroking, investment manager, custodian, SIPP operator, crowdfunder, appointed representative, and MTF/OTF routes.
  • - Check whether the platform holds or controls client money or safe custody assets; if it does, build a CASS position that covers firm type, CMAR expectations, annual questionnaire, reconciliations, bank/custodian arrangements, and senior ownership.
  • - Tie permissions, investment types, client types, Consumer Duty outcomes, financial promotions, outsourcing, cyber resilience, financial resources, and wind-down evidence to the actual platform model.

Pre-draft questions

  • - Does the platform give advice, arrange deals, receive and transmit orders, deal as agent, safeguard and administer assets, hold client money, operate nominee accounts, or only provide software to an authorised firm?
  • - Are users retail, advised retail, direct retail, professional, institutional, overseas, SIPP/trust clients, or adviser-intermediated clients?
  • - Which assets are available: funds, shares, ETFs, bonds, model portfolios, structured products, private market interests, cash, or pensions wrappers?
  • - Who owns SMF16, SMF17, SMF18 or other CASS responsibility, MLRO, finance, operations, product governance, complaints, outsourcing, technology, and wind-down?
  • - Do the regulatory business plan, client terms, custody agreements, bank account setup, fee model, website, service description, and FCA Register expectations describe the same platform operation?

Evidence pack

Platform permission and client journey map

  • - End-to-end workflow covering marketing, onboarding, KYC, appropriateness or suitability boundaries, product universe, order routing, execution, settlement, custody, client money, fees, reporting, complaints, and exit.
  • - Permission matrix covering arranging, dealing as agent, safeguarding and administration, client money, advising where relevant, managing investments where relevant, financial promotions, agreeing to carry on activities, and launch restrictions.
  • - Boundary memo separating investment platform, adviser platform, execution-only service, wealth/stockbroking, custodian, SIPP operator, crowdfunder, appointed representative, white-label software provider, and MTF/OTF assumptions.

CASS, custody, and financial resources

  • - Client money and safe custody asset memo covering hold/control facts, bank and custodian accounts, nominee structure, mandate controls, fee deduction, corporate actions, reconciliation, recordkeeping, breach escalation, and client asset return planning.
  • - CASS classification working file, annual questionnaire owner, CMAR assumption for medium or large firms, SMF18 or CASS responsibility evidence, and management information for client asset oversight.
  • - Three-year forecasts, financial-data template, capital and prudential assumptions, insurance, stress cases, wind-down plan, platform exit arrangements, and client communication plan if the platform fails or transfers books.

Technology, conduct, and operating controls

  • - Technology architecture, access control, change management, resilience, incident response, cyber controls, vendor due diligence, outsourcing register, service levels, exit plans, and business continuity evidence.
  • - Consumer Duty and product governance evidence covering target market, value, communications, vulnerable clients, complex or high-risk products, costs and charges, complaint routes, and outcome monitoring.
  • - Connect application pack with consumer-investments source log, forms, IT questionnaire, controllers and senior manager evidence, CASS attachments, fee evidence, case-officer response log, and post-approval register verification.

People and governance

  • - A platform application needs named owners for product governance, advice/non-advice boundaries, order flow, CASS, operations, technology, financial crime, complaints, financial resources, Consumer Duty, and wind-down.
  • - SMF18 or the relevant CASS responsibility file should explain real authority over client asset controls, not only a title in the organisation chart.
  • - Where the model uses a third-party custodian, broker, bank, administrator, outsourced technology provider, or adviser network, the applicant still needs oversight, service-level, exit, and escalation evidence.
  • - Senior management should be able to explain how the platform prevents out-of-scope products, unapproved promotions, unauthorised advice, stale client classification, and client asset errors.

Forms and submission

  • - Use the FCA consumer-investments firm page as the firm-type route check because investment platforms sit in that consumer-investments application family.
  • - Prepare FCA Connect forms, business plan, financial forecasts, controller and senior manager forms, IT questionnaire, platform workflow evidence, CASS memo, custody agreements, policies, and fee evidence before submission.
  • - Use the FCA client money and assets page to build the CASS classification, annual questionnaire, CMAR, SMF18, client asset return, and breach-escalation evidence where the platform holds or controls client money or safe custody assets.
  • - After authorisation, verify permissions, requirements, approved persons, directory persons, CASS ownership, and warning/clone-firm context on the FCA Financial Services Register before launch communications.

Timeline risks

  • - Platform applications slow down when the applicant cannot explain whether it is execution-only, advised, arranged through advisers, white-label software, wealth/stockbroking, custodian, or market-operator-like activity.
  • - CASS uncertainty, unclear custodian contracts, weak reconciliation evidence, unsupported technology resilience, and vague client asset return planning can create multiple follow-up rounds.
  • - Retail-facing investment platforms need Consumer Duty, product governance, costs and charges, complaint, vulnerable-client, and high-risk investment controls before submission, not after launch.
  • - The FCA authorisation page states complete FSMA applications are usually assessed within 6 months, while incomplete applications can take up to 12 months.

Questions to ask advisers

  • - Which permissions are needed for the platform's first release, and which should be restricted or delayed until evidence improves?
  • - Does the CASS memo match actual client money, custody, nominee, mandate, fee deduction, reconciliation, custodian, and wind-down facts?
  • - Is the service execution-only, adviser-intermediated, advised, discretionary, arranging, dealing, custody, SIPP-related, or several of those at once?
  • - What evidence proves that technology, vendors, CASS controls, Consumer Duty outcomes, and senior ownership are ready before launch?

Common mistakes

  • - Calling the product a software platform while the client journey still includes arranging, dealing, custody, client money, or advice-like activity.
  • - Treating a third-party custodian as a complete answer to CASS without documenting hold/control facts, reconciliations, mandates, fee deductions, and senior ownership.
  • - Using wealth or adviser templates that do not explain platform technology, order routing, client asset flows, vendor controls, and exit arrangements.
  • - Launching website, app, or adviser-facing claims that describe broader permissions than the FCA application requests.

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.