UK Financial Services Authorisations: Open for Business?

On 15th July 2025 the Chief Executive (CEO) of the UK Financial Conduct Authority (FCA) sent a letter to the Chancellor outlining new Key Performance Indicators (KPIs) to improve the FCA authorisation process and related procedures. This move forms part of a wider regulatory reform effort aimed at revitalising the UK financial sector.

The letter complements the Chancellor’s new “Regulation for Growth” agenda as set out in her annual Mansion House speech, given on the same date. A series of dire economic figures has left the Government desperately searching for ways to attract financial services businesses back to the UK. In this article, we summarise the key takeaways from the CEO’s letter and set out how we can help if you choose to take advantage of this new drive to thrive.

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What’s changing with FCA authorisation?

The CEO announced that the regulator is introducing new targets to streamline the processing of various applications. These include:

  • Investment Firm applications for authorisation and variation of permission applications which represent a significant change to an applicant’s existing business model: cutting time to make a decision on complete applications from six (6) months to four (4) months and from 12 months to 10 months for incomplete applications;
  • variation of permission (VoP) applications: providing the request permissions are closely aligned with the applicant firm’s existing business model, completed applications will be considered within three (3) months and incomplete withing six (6) months; 
  • Payment and E-Money Institution applications: complete applications for authorisations and registrations to be decided in three (3) months (no change), with a decision being made regarding incomplete applications within 10 months (down from 12); and
  • Senior Manager Function (SMF) approvals: soft target of processing all applications within 35 days, more ambitious than the proposed revised statutory deadline of two (2) months, reduced from three (3) months.

Is the FCA lowering its expectations regarding the standard of applications expected?

No.  Sheree Howard, executive director of authorisations at the FCA said: “…we will maintain a robust authorisation process.” Firms should continue to expect high standards and rigorous checks across all areas of the FCA authorisation process.

Is the FCA increasing its capacity to meet the new targets?

Yes. The FCA is expanding its Early and High-Growth Oversight and pre-application support functions. The regulator has also taken steps to increase digitisation. 

In our opinion, this is very good news. Utilising the FCA’s pre-application support channels is an excellent way of teasing out issues before a submission is made. It provides an opportunity to test the feasibility of an idea early on. This can save a lot of time and money if the FCA provides feedback that a proposal is not viable. Furthermore, opening a pre-application window in advance of formal submission gives an applicant time to build a good working relationship with a case officer. A firm can usually send documentation to the case officer for review during a pre-application window. Again, this is a great opportunity to iron out issues before making a formal submission, reducing the likelihood that the FCA will declare an application “incomplete”, thereby “stopping the clock”.  Moreover, a firm can usually send completed drafts of documentation to the FCA whilst working on pulling together other documents in tandem, something which maintains a sense of progress in what can be a gruelling process. 

What has the FCA’s record of processing applications been like lately?

The FCA has made significant progress in processing applications over the past few months. For example, in Q1 2024/25:

  • 96.8% of investment firm authorisations were completed within statutory deadlines, with a median determination time of 106 days;
  • 100% of VoP applications were processed within statutory deadlines, with a median determination time of 82 days; 
  • 92.3% of authorisations under the Payment Services Regulations were processed within the relevant deadline, while 100% of authorisations under the Electronic Money Regulations were actioned; and
  • 99.4% of SMF applications were determined, with a median determination time of 36 days. 

These figures represent significant progress since the delays and volatility seen in the immediate post-COVID era. It will be interesting to see if the FCA can maintain these service levels once its recalibrated targets enter into force in 2026. 

How does the FCA intend to gauge its success in meeting the new targets?

From 2026 the FCA’s quarterly KPIs will account for the new targets and statutory deadlines. These changes signal a more transparent, data-driven FCA authorisation process moving forward.

How can C&G help with FCA applications and registration support

The FCA’s CEO emphasised that rigid deadlines are likely to lead to increased refusal rates.  In our view, so could tighter deadlines. This is because case officers will be under increased pressure to turn around complex applications in a shorter timeframe but applying the same rigorous standards. 

Unparalleled experience

This is where we come in. We have extensive experience in preparing regulatory applications and liaising with the FCA, gained at the C-suite level in-house. Our consultants can triangulate a range of experiences and professional disciplines to deliver a positive outcome for our clients. If you are considering making an application and would like premier expert support: 

Contact us today to learn how we can help you succeed:

References

HM Treasury. (2025, July 15). Rachel Reeves: Mansion House 2025 speech. GOV.UK. Retrieved 16 July 2025, from https://www.gov.uk/government/speeches/rachel-reeves-mansion-house-2025-speech

Financial Conduct Authority. (2025, July 15). FCA sets faster targets for authorisations. FCA News. Retrieved 16 July 2025, from https://www.fca.org.uk/news/news-stories/fca-sets-faster-targets-authorisations

Financial Conduct Authority. (2025, May 21). FCA authorisations operating service metrics 2024–25 Q4. FCA Data. Retrieved 16 July 2025, from https://www.fca.org.uk/data/fca-authorisations-operating-service-metrics-2024-25-q4