Common licence or registration routes
- - FCA Part 4A authorisation for investment firms
- - Managing investments or portfolio management permissions
- - Advising, arranging, dealing, and custody permissions as relevant
- - Approved senior manager and certification arrangements under SM&CR
Individual application requirements
- - Senior Manager Function approval where a controlled function applies
- - Certification for relevant staff under SM&CR where applicable
- - Conduct Rules training and fit and proper assessment
- - Clear allocation of responsibility for compliance, money laundering reporting, and operations
Corporate application 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.
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
Practical notes
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.
Practical difficulty: Very high
Firms that need a UK regulatory footprint, institutional credibility, or access to UK clients and markets with mature governance.
Watch-outs
- - A consultant can help, but the FCA still expects the firm to understand and own its application.
- - SM&CR is not just an HR exercise; it shapes accountability evidence.
- - Consumer-facing and client asset models can materially increase scrutiny.