If you’re preparing to apply for FCA authorisation, you’ve probably realised it’s not just about filling in forms. The FCA wants to see that your business is genuinely “ready, willing, and organised” – not just in words, but in action.
The regulator recently published new guidance showing what good (and poor) applications look like. It’s full of lessons for firms that want to get it right the first time and is required reading if you’re considering full FCA authorisation
Jacqueline Sinclair from Regnition (helping scaling businesses navigate the FCA authorisation process) shares her top 5 takeaways to keep in mind before you hit “submit.”
1. Be honest about your people
The FCA really cares about who’s running your business. Your application should show that key individuals have the right skills and experience. If there are gaps, don’t gloss over them, explain how you’re addressing them. If you’re a boot-strapping startup, it’s likely you’ll have people wearing multiple hats. That’s okay, but the FCA will want to understand how they devote sufficient time to each of their roles.
Transparency goes a long way. A clear governance or organisational chart and a sensible recruitment or training plan can make all the difference.
2. Ditch the generic policies
If your compliance documents look like they came from a template pack (or worse still, from Chat GPT!), the FCA will spot it immediately.
Policies need to reflect how your business actually works, and show consideration of your customer type, product, and business-specific risks. Repeating FCA rules word-for-word or using “off-the-shelf” frameworks suggests the business doesn’t fully understand its obligations.
Ask yourself: would this policy still make sense if the FCA asked how it works in practice?
3. Show the money
Financial stability is one of the biggest tests. The FCA expects companies to evidence that they have enough capital and cash flow to operate sustainably.
Use the FCA’s financial templates, include clear notes, and check every figure. Missing, inconsistent, or overly optimistic data is a fast track to follow-up questions.
If you were investing in your own company, would you be confident in the numbers you’ve presented?
4. Demonstrate real UK presence
For overseas businesses, the FCA wants to see genuine commitment to the UK market, not just a token nameplate address or local consultant.
Make sure your governance, reporting lines, and decision-making structures show clear accountability in the UK, and to your UK customers. The FCA needs to know where responsibility really sits.
5. Own your application
Consultants and legal advisers can help, but the FCA expects senior management to take ownership and understand their regulatory obligations. Over-reliance on third parties can signal that leadership isn’t ready to run a regulated business.
Your application should sound like it comes from you, not your lawyer.
Final thought
FCA authorisation isn’t a box-ticking exercise. It’s about showing you understand the regulatory landscape and have built a business that can operate responsibly within it.
If you invest the time to tailor your application, be open about your people, and back it up with evidence, you’ll not only speed up the authorisation process, you’ll also lay the foundations for long-term, sustainable compliance.
Regnition is a boutique regulatory compliance firm based in London, focused on making compliance uncomplicated. From first licence to global expansion, they provide pragmatic, plain-speaking advice to innovative financial services firms, focusing on insurance and insurtech firms, crypto firms, fintech firms and payments businesses.
