What are my options if I need FCA authorisation?

Start with the activities, not the route

Each route only works if it covers the specific regulated activities you carry on. Before comparing options, it helps to be clear which of your activities are regulated, which are not and which depend on an exclusion. A written opinion often sets that out, and the answer can change which route makes sense. A business with one regulated activity on the edge of its model faces a different choice from one whose core service is regulated.

Direct authorisation

Direct authorisation means applying to the FCA for your own permission under Part 4A of the Financial Services and Markets Act 2000 (FSMA), or for authorisation or registration under the payment services or e-money regulations. The FCA assesses whether you meet the threshold conditions, which cover matters such as your business model, your resources, the suitability of your people and whether you can be effectively supervised.

An application usually involves a regulatory business plan, financial projections, policies and procedures, and details of the people who will run the regulated business. Once authorised, a firm is supervised by the FCA, pays fees and levies, and must meet ongoing rules and reporting requirements. Most firms authorised under FSMA are also within the Senior Managers and Certification Regime.

Direct authorisation gives you control and independence, and it suits many businesses whose core activity is regulated. It is also the more demanding route to set up and run. Specialists in preparing applications can help. See directauthorisation.com for more on this route.

Becoming an appointed representative

An appointed representative (AR) is a business that carries on regulated activities under a contract with an authorised principal, which accepts responsibility for what the AR does in carrying on that business. Under section 39 of FSMA the AR is then an exempt person for those activities. The FCA’s rules for principals and ARs are in SUP 12.

The principal must have the relevant permissions itself, and only some types of regulated business can be carried on as an AR. The principal oversees the AR, often charges for doing so, and can end the arrangement under the contract. Some firms are appointed as introducer appointed representatives, a narrower role that is limited to making introductions to the principal or its group and distributing non-real time promotions for products or services available from or through the principal.

The AR route can let a business operate under an established firm’s permissions without its own authorisation, but it brings dependence on the principal and its terms. See appointedreps.com for more, and authorisation and AR compared.

Changing the model

Sometimes the activity that brings a business inside the perimeter is not central to it. In that case it may be possible to change the model so the regulated activity is not carried on at all, for example by changing who you lend to, by using an authorised payment provider rather than holding customer funds, or by narrowing what an introduction involves.

A change of model has to be real. It needs to show in your contracts, processes, fees and marketing, and the reasoning behind it is often worth setting out in a written opinion so that you, your bank and your partners can rely on it.

Working with an authorised firm

Another option is for an authorised firm to carry on the regulated activity while your business does the parts that are not regulated. Distribution, white label and referral arrangements are common examples. The split has to be genuine. If your role still amounts to arranging, broking or advising, the arrangement does not solve the problem unless you are covered as an AR or fall within an exclusion.

If you are already authorised

An authorised firm that needs to add an activity usually applies to vary its permission rather than make a new application. Until the variation is granted, the new activity should not be carried on.

Payments, e-money and crypto

Payment and e-money businesses have their own routes, including registration as a small institution or becoming an agent of an authorised payment institution. See payments and e-money. Cryptoasset firms face a new authorisation regime. The FCA’s authorisation gateway opened on 30 September 2026, the FCA expects firms that want to keep operating in the UK to apply by 28 February 2027 and the regime goes live on 25 October 2027. Firms registered under the Money Laundering Regulations must apply, because registration does not convert automatically. See cryptoreg.co.uk for more on crypto authorisation.

Your marketing is a separate test

If the issue is your promotions rather than your activities, the usual route is to have them approved by an authorised firm or to fit them within an exemption in the Financial Promotion Order. Since 7 February 2024 an authorised firm generally needs a specific FCA permission to approve financial promotions for unauthorised businesses, with limited exceptions such as promotions within its own group or of its appointed representatives. How section 21 approval works and why the two tests are separate.

How long it takes

Timeframes depend on the route, the FCA and the quality and completeness of the application or arrangement. FSMA sets outer limits for the FCA to decide applications, but the actual time varies. A specialist can give you a realistic view for your circumstances.

Common misunderstandings

When a written opinion helps

Before you commit to a route, a written legal opinion can set out which of your activities are regulated and which are not, so you apply for the right permissions or restructure the right part of the business. It can also document why a changed model sits outside the perimeter. How written opinions work

If you are inside the perimeter, we can introduce you to specialists in direct authorisation, AR arrangements and section 21 approval. The firms we introduce you to pay us an introduction fee. How it works