Financial Conduct Authority

UK FCA wealth and stockbroking authorisation pack

A practical evidence pack map for UK wealth management, stockbroking, and wholesale-broker FCA authorisation, including advising, arranging, dealing, CASS, MIFIDPRU, SM&CR, order handling, financial crime, Consumer Duty, and register readiness.

Route focus

A wealth or stockbroking application should prove whether the firm advises, arranges, deals as agent, manages portfolios, holds client money or safe custody assets, operates retail or wholesale flows, and can evidence capital, systems, order handling, CASS, financial crime, Consumer Duty, and senior accountability from day 1.

Who this helps

  • - UK wealth managers and stockbrokers preparing direct FCA authorisation
  • - Wholesale brokers, arrangers, and adviser/arranger models checking advising, arranging, and dealing permissions
  • - Execution, advisory, discretionary, model portfolio, or introducing firms deciding whether CASS or MIFIDPRU changes the route
  • - Compliance, operations, finance, CASS, MLRO, and SMF teams preparing a broker or wealth evidence pack

Licence scope

  • - Map whether the firm provides investment advice, discretionary management, arranging, making arrangements with a view to transactions, dealing as agent, custody/safeguarding, reception/transmission of orders, financial promotions, or platform-like workflows.
  • - Separate consumer-investment wealth/stockbroking models from wholesale-broker authorisation, investment manager authorisation, platform authorisation, corporate finance, custodian, MTF/OTF, and appointed representative routes.
  • - Check client type, retail versus professional scope, MiFID investment firm status, MIFIDPRU or IPRU-INV prudential route, Permanent Minimum Requirement, Fixed Overhead Requirement, client asset permissions, and CASS firm type.
  • - Tie the application to FCA sector expectations for wealth and stockbroking firms: financial crime, Consumer Duty outcomes, high-risk or complex investments, costs and charges, client assets, and senior accountability.

Pre-draft questions

  • - Does the firm only introduce or arrange, or will it advise, receive/transmit orders, deal as agent, manage portfolios, hold client money, safeguard assets, or control settlement instructions?
  • - Are clients retail, professional, eligible counterparties, vulnerable consumers, high-net-worth, overseas, or wholesale-only, and do suitability, appropriateness, product governance, and Consumer Duty controls match that mix?
  • - Which SMFs, certification staff, registered advisers, dealers, operations, CASS, MLRO, finance, complaints, best execution, and trade-reporting owners are needed?
  • - Which financial-data template, capital injection evidence, 3-year forecast, prudential category, CASS position, clearing/custody agreement, vendor setup, and business continuity evidence are ready?
  • - Do the regulatory business plan, website, order forms, client agreements, fee schedule, disclosures, product list, execution policy, and Financial Services Register expectations describe the same broker/wealth model?

Evidence pack

Permission, client, and order-flow map

  • - Step-by-step journey covering marketing, onboarding, client classification, suitability or appropriateness, advice, order taking, arranging, dealing as agent, execution, settlement, custody, fees, complaints, and register checks.
  • - Permission matrix covering advising on investments, arranging deals, making arrangements with a view to transactions, dealing as agent, managing investments where relevant, agreeing to carry on regulated activities, and client money or safeguarding permissions.
  • - Boundary memo separating wealth/stockbroking, wholesale broker, investment manager, corporate finance, platform, custodian, MTF/OTF, appointed representative, and mere introducer routes.

CASS, operations, and financial resources

  • - Client money and safe custody asset memo, CASS classification, clearing/custody/settlement map, bank and custodian account evidence, reconciliation process, CASS oversight, and client asset return planning.
  • - Three-year forecasts, wholesale or consumer-investment financial-data template, historical accounts if trading, capital injection evidence, MIFIDPRU or IPRU-INV analysis, PMR/FOR assumptions, liquidity runway, and wind-down plan.
  • - Systems evidence for order management, trade surveillance, best execution, transaction reporting where relevant, communications recording, complaint handling, cyber, outsourcing, business continuity, and management information.

Conduct, financial crime, and senior ownership

  • - SM&CR map, statements of responsibility, certification, Conduct Rules, dealer/adviser competence, compliance monitoring, MLRO, CASS owner, finance, operations, and complaints ownership.
  • - Financial crime, sanctions, fraud/scam controls, market abuse, high-risk or complex investment controls, product governance, Consumer Duty outcomes, vulnerable clients, costs and charges, conflicts, inducements, and personal account dealing.
  • - FCA Connect application pack, required firm-type supplement, MiFID/MIFIDPRU notes where relevant, fee evidence, source log, case-officer response tracker, and post-approval register verification.

People and governance

  • - A broker or wealth firm needs named owners for advice, dealing, best execution, CASS, financial crime, complaints, product governance, Consumer Duty, financial resources, and wind-down.
  • - Retail-facing stockbroking should not be treated as a light-touch wholesale route; client classification, suitability or appropriateness, Consumer Duty, costs and charges, and vulnerable-client evidence matter.
  • - Where the firm uses a clearing broker, custodian, platform vendor, overseas group desk, or appointed representative network, the applicant still needs control, oversight, and escalation evidence.
  • - Dealer, adviser, portfolio manager, operations, CASS, compliance, and MLRO competence should be mapped to the actual products and client types, not only job titles.

Forms and submission

  • - Use the FCA consumer-investments page for wealth/stockbroking models and the wholesale brokers page where the firm is a wholesale broker or adviser/arranger.
  • - Prepare Connect forms, MiFID or non-MiFID forms, MIFIDPRU supplement where relevant, firm-type supplement, financial forecasts, financial-data template, controllers/individuals forms, IT questionnaire, checklist, and declaration.
  • - Use the FCA wholesale markets page where the model is wholesale: regulatory business plan, 3-year financial forecast, UK principal place of business, bank account, client money/assets information, capital injection evidence, and sector letters.
  • - After approval, verify permissions, requirements, approved persons, directory persons, investment-firm register context where relevant, and warning/clone-firm checks on the FCA Financial Services Register.

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.
  • - Broker and wealth applications slow down when order flow, CASS, clearing/custody, client classification, prudential category, capital injection, or financial crime controls are vague.
  • - Wholesale-broker evidence can fail if advising, arranging, making arrangements, dealing as agent, and regulated-advice boundaries are not mapped to the actual mandate and compensation flow.
  • - Retail wealth and stockbroking evidence can fail if Consumer Duty, suitability/appropriateness, costs and charges, high-risk investments, vulnerable clients, and scam/fraud controls are treated as post-approval projects.

Questions to ask advisers

  • - Is the firm a wealth/stockbroking consumer-investment firm, wholesale broker, investment manager, platform, custodian, corporate finance firm, or several at once?
  • - Which permissions and investment types are needed for advice, arranging, dealing, execution, settlement, custody, and ongoing service?
  • - Does the CASS memo match client money, safe custody assets, mandates, clearing, custody, fees, settlement, and wind-down facts?
  • - Can the firm prove capital, financial resources, financial crime controls, Consumer Duty outcomes, order supervision, and senior ownership before submission?

Common mistakes

  • - Calling a brokerage or arranging workflow an introducer model without checking permissions, compensation, client communications, and order flow.
  • - Leaving CASS and client asset analysis to the clearing broker or custodian instead of documenting the applicant's role and controls.
  • - Requesting broad dealing, advising, arranging, and custody permissions without enough capital, systems, people, and financial crime evidence.
  • - Using a wholesale template for a retail wealth model that needs Consumer Duty, suitability, costs and charges, and vulnerable-client controls.

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.