Obtaining FCA authorisation is a demanding and rigorous process. Applications fail due to inadequate preparation or an inability to demonstrate live operations. Agnos Consulting secures regulatory approvals from the FCA, FINTRAC, the DFSA and Central Banks.
Speak to StevenUnder the Payment Services Regulations 2017, any firm providing payment services in the UK must be either registered or authorised by the Financial Conduct Authority. There are two categories.
For firms processing under €3 million per month in payment transactions. Registration is simpler but comes with significant restrictions — safeguarding applies.
Full authorisation under the PSR 2017. No volume cap. Significantly more demanding application — the FCA expects a comprehensive regulatory business plan, a robust AML framework and demonstrable operating readiness, including systems and the use of third parties.
Required if your business model involves holding funds — prepaid cards, digital wallets or stored value products, such as holding funds on account. Governed by the Electronic Money Regulations 2011. Capital requirements and safeguarding rules are distinct from a standard PI licence.
The FCA does not publish a pass mark. What they assess is whether your firm is ready to operate safely, compliantly and sustainably. These are the areas where most applications fall short.
The centrepiece of your application. The FCA expects a detailed, credible plan covering your business model, target market, revenue projections, capital adequacy, risk appetite and governance structure. Vague or generic plans are rejected. The plan must demonstrate that you understand the regulatory environment you are entering, including treating customers fairly.
A documented anti-money laundering programme is mandatory. This must include your customer due diligence and onboarding procedures, risk assessment methodologies, transaction monitoring and payment screening approach, SAR filing process and MLRO responsibilities. The FCA expects a framework that is proportionate, risk-based and operational — not theoretical.
You must demonstrate how you will protect client funds throughout a transaction's lifecycle. This may require the use of additional liquidity to bridge the gap between the receipt of client money and the release of the underlying payment, so as not to use funds belonging to other customers. Your arrangements must be documented and the process auditable from day one.
All individuals performing significant management functions must pass FCA scrutiny. This includes your MLRO, compliance officer and any directors. The FCA will assess their experience, qualifications and fitness. Gaps in the senior management teams' experience are a common reason for delay or refusal.
You must demonstrate that you hold adequate own funds throughout the application process and beyond. It may be up to 10 months before approval is granted and a further 12 months before break-even is reached. A detailed cash flow statement is required. For an Authorised PI, the minimum own funds requirement depends on your payment service categories. For an EMI, the minimum initial capital is €350,000. Projections must be stress-tested.
The FCA expects you to demonstrate that your systems, controls and policies are in place before authorisation is granted — not after. This includes your payment processing infrastructure, IT security arrangements and business continuity planning.
The FCA's withdrawal and refusal rate for payment institution applications is significant. Here are some of the most common reasons.
Lack of safeguarding accounts at an authorised credit institution and the incorrect calculation of the daily safeguarding requirement. This is among the most frequent reasons for refusal.
A business plan that reads like a template rather than a genuine operational blueprint. The FCA looks for specificity — named partners, real revenue assumptions and credible market analysis.
An AML policy that exists on paper but has no operational substance. The FCA expects your framework to reflect the actual risks of your specific business model and customer base.
A lack of a fully functioning payment gateway to process payments to beneficiaries. The FCA expects operational readiness to be demonstrated, not promised.
Firms that apply before they have sufficient own funds in place. Capital requirements must be met at the point of application, not at authorisation.
Appointing an MLRO without demonstrable AML experience. The FCA will assess whether your MLRO is genuinely qualified to hold the role — not simply senior enough.
Steven Faulkner has obtained regulatory approvals from the FCA, FINTRAC, the DFSA and Central Banks. Every engagement is conducted personally — no junior consultants, no delegation.