When applying for an authorisation with the Financial Conduct Authority (“FCA”), the quality of your application determines whether you move swiftly towards approval or face repeated scrutiny and costly delays. The FCA’s September 2025 publication, “Authorisation and registration applications: good practice and areas for improvement,” offers a clear blueprint for firms that wish to succeed.
The guidance focuses on three core areas every applicant must address effectively: people, policies and procedures and financial resources. Done well, these demonstrate that your business is “ready, willing and organised” with regulatory expectations. Done poorly, they create significant barriers to authorisation and may raise questions from the regulator about your firm’s readiness.
What Good Applications Include
The FCA outlines practical examples of strong submissions. At their core is clarity, ownership and an ability to demonstrate that your firm can operate responsibly within the UK regulatory framework. A strong application goes beyond ticking boxes, it tells a coherent and credible story about your people, systems and financial resilience.
On People
High-quality applications show that firms have given careful thought to those responsible for running the business. This includes conducting fit and proper assessments for senior managers and key staff, in line with the Systems & Controls rules of the FCA Handbook, and providing clear ownership and control structures.
Furthermore, applications should acknowledge any skills gaps and detail realistic plans to address them, whether through training, hiring or external support. The FCA also expects firms to align remuneration policies with good customer outcomes, as emphasised under the Consumer Duty.
Strong applications typically include:
- Fit and proper checks on senior managers and key staff.
- Transparent ownership and control charts.
- Realistic plans for bridging identified skills gaps.
- Incentive structures that prioritise customer outcomes over sales volume.
On Policies and Procedures
Successful applications contain policies and procedures that are both comprehensive and tailored to the firm’s business model. The FCA recommends using its business plan template, ensuring all necessary information is included.
Applications should also outline governance structures with UK oversight, even where overseas operations exist. Mapping the permissions sought to specific regulated activities demonstrates an understanding of the regulatory perimeter (with specific references to the PERG rules in the Handbook). Embedding the Consumer Duty across operations and customer journeys is also a key indicator of readiness.
Best practice examples include:
- Use of the FCA’s business plan template.
- Clear governance and oversight structures rooted in the UK.
- Mapping permissions directly to business activities.
- Integration of the Consumer Duty into policies and procedures.
On Financial Resources
Financial resilience is central to any application. Strong submissions include forecast financials using FCA templates, supported by assumptions that justify projected revenues and costs. Firms should also provide evidence of funding commitments, including contingency plans where relevant. Finally, for operating firms, including historic financial accounts offers a fuller view of the firm’s stability.
Firms demonstrating good practice:
- Use FCA-approved financial forecast templates.
- Include detailed assumptions underpinning financial projections.
- Provide evidence of committed funding sources and contingency planning.
- Submit historic financial accounts to support their application.
Common Mistakes That Delay Approval
Avoiding known pitfalls is just as important as following best practice. The FCA has highlighted recurring issues across authorisation and registration submissions, many of which stem from a lack of preparation or an over-reliance on templates and external advisers.
On People
One major concern is an over-reliance on external compliance consultants. While the FCA continuously advises firms to utilise the expertise of regulatory consultants to provide support, the FCA also expects firms to demonstrate internal accountability and understanding of the procedures and regulatory scope of their application. Another issue is unclear time commitments from key individuals with multiple roles. Some firms also fail to establish a genuine UK presence, a requirement under the FCA’s Threshold Conditions.
Frequent issues include:
- Excessive dependence on consultants with little internal engagement.
- Vague time commitments for individuals holding multiple roles.
- Lack of a meaningful UK base or appropriately located staff.
On Policies and Procedures
Firms often submit generic policies that do not align with actual business practices. The FCA expects documentation that is specific, practical and tied to operational realities. There is often insufficient consideration of vulnerable customers, a requirement under CONC 2.2 and PRIN 2A. This misalignment creates risk and signals poor preparedness.
Examples of weak practice:
- Use of untailored, boilerplate policies.
- Failure to address customer journeys, including vulnerability scenarios.
- Inconsistencies between documented policy and actual operations.
On Financial Resources
Weak financial evidence is a consistent theme. Applications often lack historic financials, present inconsistent forecasts or fail to address key prudential requirements such as capital adequacy (IFPR requirements under MIFIDPRU). These gaps raise credibility concerns and often lead to unwanted delays.
Common shortcomings include:
- Omission of historic financial accounts.
- Inaccurate or contradictory financial forecasts.
- No demonstration of how prudential resource requirements will be met.
How Firms Can Elevate Their Applications
Firms seeking authorisation should adopt a structured, evidence-led approach to enhance the quality of their submission:
- Audit Your Team
- Map out responsibilities and availability.
- Identify skills gaps and prepare development or hiring plans.
- Tailor Your Policies
- Avoid generic templates.
- Ensure policies reflect operational practice and include customer outcomes.
- Strengthen Your Finances
- Provide both historic and forecast financials with clear assumptions.
- Include funding sources and contingency provisions.
- Embed the Consumer Duty
- Integrate fair value and customer focus across policies and systems.
- Review Before Submission
- Engage compliance professionals to perform a pre-submission review.
Authorisation should not be viewed as a regulatory hurdle, but as an opportunity to demonstrate your firm’s integrity and readiness.
How Can Complyport Help?
Complyport has extensive experience supporting firms through the FCA authorisation process and beyond. Our services include:
- Authorisation Support: We help you prepare and submit complete, tailored applications, ensuring full alignment with FCA expectations and reducing the risk of delays.
- Regulatory Business Plan Creation: Our consultants work with you to draft business plans that meet FCA requirements, articulating your governance, risk and compliance framework clearly.
- Consumer Duty Implementation: We guide you in embedding Consumer Duty across your business, from governance structures to customer-facing materials, ensuring ongoing compliance.
- Financial Forecasting and Prudential Guidance: Our team assists in developing robust financial forecasts and assessing capital adequacy in line with MIFIDPRU or other applicable regimes.
- Ongoing Compliance Support: From regulatory reporting to policy development, we offer tailored ongoing compliance solutions that scale with your business.
Book a meeting with one of our Subject Matter Experts today to find out how we can streamline your authorisation journey and ensure long-term compliance success.
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