Topic: FCA feedback on authorisation applications – what firms need to get right
Overview:
The Financial Conduct Authority (FCA) has shared key observations from its review of authorisation applications, including areas of good practice and suggested areas for improvement. These insights will help firms meet the regulator’s standards when applying for authorisation or approval as an Appointed Representative.
The FCAs feedback is centred around three core themes:
- People – Firms must have the people with the right skills, experience, and capacity to deliver financial services competently.
- Processes – Firms need to have documented and embedded processes and policies that reflect their specific business.
- Financial Resources – Firms should demonstrate they have appropriate financial resources to support the scale and nature of their business.
By setting clearer expectations, the FCA aims to improve the quality of applications, reduce delays, and increase the likelihood of approval.
In relation to People, the FCA welcomed applications where firms had provided their own suitability assessment of Approved Persons, clear ownership structure charts identifying relevant parties and controllers, acknowledged resource gaps and provided clear plans to fill them, and explained how staff incentives support good customer outcomes rather than merely driving sales volumes. Suggested improvements included applicants avoiding over-reliance on compliance consultants and possessing an understanding of their regulatory obligations, demonstrating how individuals with multiple responsibilities will allocate their time across different roles to competently fulfil their duties, and evidencing a genuine UK presence.
On Processes, good practice included utilising the FCA sample business plan, documenting decision making and reporting lines for UK operations particularly where parts of operations are overseas, and demonstrating how permissions applied align with intended business activities. Additionally, firms that implemented Consumer Duty throughout their internal policies, procedures, systems and controls, rather than just referencing the rules, were appreciated. Suggested improvements include tailoring firm policies to the business and demonstrating implementation in practical terms by the firm, ensuring policies align when considered together, and designing more robust systems and controls to protect customers.
Regarding Financial Resources, the FCA noted submitting forecasts using FCA templates including assumptions and supporting notes, and providing evidence of funding as good practice. Areas for improvements included submitting historical financial accounts, more accurate data and providing sufficient detail to verify that how prudential requirements would be met.
At Brooklands, we have a deep understanding of the FCA’s standards and embed these principles throughout our onboarding and oversight processes. We work closely with clients from the outset and on an ongoing basis, to ensure their documentation meet the level of rigour expected under regulatory scrutiny. Through thorough due diligence and continuous engagement, we help firms understand and meet their obligations, maintaining high standards of compliance across our network.
Link: Authorisation and registration applications – good practice and areas for improvement | FCA Published: 11/09/2025
Title: Authorisation and registration applications – good practice and areas for improvement
