A practical guide to building a clear, consistent application that reflects how the business will actually operate.
A strong application is not the one with the most pages. It is the one in which the form, business plan, customer journey, policies, financial information and supporting evidence tell the same credible story.
The FCA says applicants should be ready, willing and organised. In practice, that means the proposed activity has been thought through, the documents are final rather than draft, and the people responsible for the firm can explain what has been submitted.
1. Confirm the regulatory perimeter and permissions
Describe each step the firm will take and identify which steps may be regulated. Distinguish credit broking, lending, consumer hire and any connected debt activity. Record any proposed unregulated activity as well. The application should explain why authorisation is required and why the selected permissions match the operating model.
2. Map the end-to-end customer journey
Start before the finance conversation and finish after the agreement is entered into. Cover advertising, initial contact, finance explanations, introductions, applications, disclosures, lender decisions, complaints and support for customers experiencing difficulty where relevant.
For a secondary credit broker, the journey should make clear that the firm is acting as a broker rather than the lender, which providers it expects to work with and what types of agreements may be offered.
3. Prepare a tailored regulatory business plan
The regulatory business plan should connect the commercial model to the regulatory controls. It normally needs to explain the firm’s background, ownership, services, customers, distribution, income, regulated and unregulated activities, risks, governance, resources and plans.
Avoid generic claims such as “we always treat customers fairly” without explaining who does what, when it happens and how the firm checks that it works. The FCA expects the plan to be specific to the applicant and proportionate to its model.
4. Show clear ownership and competence
Set out the legal structure, controllers, senior decision-makers and reporting lines. Identify who owns consumer credit compliance, approves financial promotions, monitors customer outcomes and handles complaints. The people named in the application should understand the business model and be able to discuss the documents.
5. Make the policies operational
Policies should be usable in the real business. They should match the customer journey, staff roles, systems and third-party arrangements. A basic policy bundle may include a Compliance Manual, compliance monitoring programme, Consumer Duty Policy, complaints-handling procedure and vulnerable customers policy. The exact requirements depend on the activities and the FCA may request further policies or information during assessment.
6. Build Consumer Duty into the model
Consumer Duty should not appear as a paragraph added at the end. Explain the target market, how products or services are reviewed, how value is considered, how communications are tested for understanding, how support is provided and what management information will be used to identify poor outcomes.
7. Prepare financial and corporate evidence
The applicant—not the document preparer—must supply accurate underlying evidence. Depending on the business and the FCA’s requirements, this may include:
- company and ownership information, group charts and controller details;
- CVs and information about directors, senior managers or approved-person candidates;
- DBS checks or other fitness-and-propriety evidence where required;
- lender, broker, platform, outsourcing or introducer agreements;
- website pages, customer communications and financial promotions;
- financial forecasts, assumptions and evidence of available resources; and
- existing complaints, sales or monitoring data where the business is already operating lawfully.
Not every item applies to every firm. The point is to confirm the evidence required for the actual structure and model, rather than assume the same checklist fits every applicant.
8. Complete a consistency review before submission
Compare the FCA Connect answers against the business plan, policies, website, commercial agreements and forecasts. Check names, dates, ownership percentages, customer types, lenders, fees, commission, permissions and financial figures. Resolve contradictions before the application is submitted.
The FCA says it will not review draft application documents and expects the applicant to be accountable for the information provided. A preparer can structure and quality-check the pack, but the firm must review, approve, understand and own it.
What happens after submission?
The FCA will assess the application and will usually ask questions. It may request further information, evidence, policies or changes. The applicant must respond directly or arrange separate support if needed. Pre-submission preparation should not be presented as ongoing representation or post-submission query handling unless that service has been expressly agreed.
A five-working-day document-preparation target is therefore different from the FCA’s assessment period. The preparation target should begin only after all required information has been received and should not be described as the time needed to obtain authorisation.
Final readiness test
- Can we explain why each permission is needed?
- Does the customer journey match what staff and systems will actually do?
- Are all documents final, tailored and mutually consistent?
- Can the responsible people explain the risks and controls?
- Have we supplied the required evidence and checked every declaration?
- Do we understand that approval is an FCA decision and cannot be guaranteed?
Important information
This content provides general information only. Whether authorisation is required, which permissions apply and what supporting material is needed depend on the firm’s actual activities and circumstances. It does not constitute legal or regulatory advice. FCA rules, forms, fees and expectations can change. Check the FCA’s current requirements before applying. FCA authorisation cannot be guaranteed.