FCA Authorisation, Registration, Change in Control and Variation of Permission
The FCA does not assess your ambition. It assesses your evidence. Whether you are applying for the first time, acquiring a stake in a regulated firm or changing what your firm is permitted to do, we build the application the regulator expects to see and stay with it until the decision lands.
Founder Lee Werrell, Chartered FCSI, FF.ISP, with more than 26 years of FCA regulatory experience, supported by our senior associate consultants.
Is FCA registration enough for your business?
Only if everything you do falls within a registration regime. Registration is narrower than authorisation in scope, not lighter in scrutiny.
The FCA still assesses the people running your business and the systems and controls behind it. Your anti-money laundering systems and controls are assessed as part of that, so they need to describe your business, not a template.
Registrations we handle
- Small payment institutions and registered account information service providers.
- Small electronic money institutions.
- Money Laundering Regulations registrations, including cryptoasset businesses and Annex I financial institutions.
Not sure which route applies?
Choosing the wrong route means starting again. The line between registration, authorisation and an exclusion turns on exactly what you do, for whom and how you are paid. We settle the regulatory perimeter with you on the discovery call, before any application work begins.
What does a change in control mean for your deal?
Approval comes before completion. The FCA has up to 60 working days to assess a complete notice, and completing early can be a criminal offence.
Anyone who decides to acquire or increase control over an FCA-authorised firm must notify the FCA under section 178 of FSMA. The FCA looks at the proposed controller's reputation and financial soundness, the source of the funds being used, and what the new ownership means for the firm itself. It can pause the assessment period once to ask for more information. That makes the regulatory timetable part of the transaction timetable, and it belongs in the heads of terms, not the week before completion.
How we help buyers, sellers and target firms
- Identify every person who becomes a controller, including indirect and group controllers.
- Prepare the section 178 notices and the source of wealth and source of funds evidence behind them.
- Prepare the target firm for new ownership, including governance, SMCR arrangements and any Senior Manager applications.
- Handle the FCA's information requests so the clock keeps running.
Reducing or ceasing control?
Existing controllers who plan to reduce or give up control must notify the FCA too, although approval is not required. We can manage both sides of the transaction.
Sources: FSMA sections 178 and 189 to 191; FCA Handbook SUP 11; FCA change in control guidance.
When do you need a variation of permission?
Whenever your business moves beyond what your permission allows, and before the new activity starts.
A variation is assessed against the Threshold Conditions in the same way as a new application. The FCA will expect your governance, resources and controls to have grown with the business. Arrangements that were adequate for the firm you were are not evidence that you are ready for the firm you are becoming.
Variations we manage
- Adding new regulated activities or investment types as the business grows.
- Moving from limited to full permission for consumer credit.
- Removing permissions, limitations or requirements that no longer fit the business.
- The linked changes: new Senior Managers, revised capital and updated policies.
Before you apply
Be your own toughest critic. A short readiness review before submission finds the gaps your case officer would otherwise find for you, and answering them before submission is always faster than answering them after.
Legal basis: section 55H of the Financial Services and Markets Act 2000.
How long does the FCA take?
In the firms we have reviewed, longer than the business plan assumed. The clock starts only when the FCA treats your application as complete, so the quality of your submission is the one timing factor you control.
| Application | Statutory deadline | FCA published target |
|---|---|---|
| New authorisation, and variations that significantly change the business model | 6 months from a complete application; 12 months if incomplete | 4 months from a complete application; 10 months if incomplete |
| Variation of permission closely aligned to the existing business model | As above | 3 months from a complete application; 6 months if incomplete |
| Payment and e-money authorisations and registrations | 3 months from a complete application; 12 months in any event | 3 months from a complete application; 10 months if incomplete |
| Change in control | 60 working days from acknowledgement of the notice, which can be interrupted once for further information | — |
HM Treasury confirmed in May 2026 that it will legislate to bring the statutory deadlines into line with the FCA's targets. Until that legislation is in force, the statutory deadlines above apply. Sources: FSMA section 55V; FCA: faster targets for authorisations; FCA: change in control. Read more in our article FCA authorisations in 2026.
How do we get you there?
Engage, execute, embed. The firm you describe on paper has to be the firm that exists when your case officer calls.
Engage
A free discovery call to confirm your route and timetable, followed by a readiness review that gives you a RAG-rated view of every gap to close before anything is submitted.
Execute
We build the business plan, policies, financial information and Senior Manager applications with you, submit through FCA Connect with you, and support every response to your case officer until the decision is made.
Embed
Permission is the starting gate, not the finish line. In the first year we help you meet the commitments your application made: regulatory reporting, Consumer Duty monitoring, SMCR certification and compliance monitoring.
Why do applications stall?
In the firms we have reviewed, delay rarely comes from the complexity of the business. It comes from gaps that could have been found before submission.
- Policies adapted from generic templates that do not describe the firm's real business.
- Business plans that sell the commercial opportunity but never show how the Threshold Conditions will be met.
- Financial projections that read like a best-case scenario and do not reconcile to the capital calculations.
- Senior Manager candidates whose competence for the specific role is asserted rather than evidenced.
- Controllers whose source of wealth and source of funds are not documented.
What do firms ask us first?
Is Compliance Consultant authorised by the FCA?
No. We are an independent consultancy that advises FCA-regulated firms and firms seeking authorisation or registration. We are not ourselves authorised by the FCA.
Can you guarantee that the FCA will approve my application?
No, and you should be wary of anyone who says they can. The decision belongs to the FCA. What we do is make sure your application is complete, evidenced and consistent, which gives it the best chance of a timely decision.
Can I start trading while my application is being assessed?
No. A new firm must not carry on regulated activities until it is authorised or registered, and an existing firm must not start new activities until its variation of permission is granted.
Can we complete an acquisition while the change in control notice is being assessed?
No. The acquisition must not complete until the FCA has approved it, or the assessment period has expired without objection. Completing early can be a criminal offence.
Does your fee include the FCA's application fee?
No. The FCA's application fee is paid directly to the FCA and is separate from our professional fees. We confirm the fee that applies when we scope your work.
How much will it cost?
That depends on your route, your business model and how much preparation is already in place. After the discovery call we set out clear options with a defined scope and fixed fees, so you know the cost before you commit.
Where does your application stand today?
Tell us what you are planning and when. We will confirm the right route, a realistic timetable and exactly what the FCA will expect to see.
Making Compliance Work
Compliance Consultant | https://complianceconsultant.org | UK 0800 689 0190 | Int'l 020 8243 8620 | Discovery call: https://bit.ly/CCDiscovr
Compliance Consultant and Compliance Doctor are trading styles of UK Compliance Consultant Limited, Companies House number 14805896.
