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How a firm gets Financial Conduct Authority Part 4A permission under the Financial Services and Markets Act 2000. Covers the general prohibition, identifying your regulated activities, meeting the threshold conditions, the Connect application, Senior Managers and Certification, and anti-money laundering obligations.
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If your firm carries on a regulated activity in the United Kingdom by way of business, you must be authorised by the Financial Conduct Authority (FCA) before you start, unless an exemption applies. This is the general prohibition in section 19 of the Financial Services and Markets Act 2000 (FSMA). Authorisation means holding a Part 4A permission that lists each regulated activity you may carry on.
This guide explains how to get that permission and the obligations that come with it. For the full step-by-step submission process, follow Apply for FCA authorisation under Part 4A FSMA; this guide focuses on scoping your activities and the ongoing duties that authorisation creates.
Authorisation starts with the perimeter. You must work out exactly which regulated activities your business model involves, because your permission is granted activity by activity and you may only do what your permission lists. Regulated activities are defined in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 and include accepting deposits, dealing in or arranging investments, advising on investments, managing investments, insurance distribution, mortgage lending and consumer credit.
Use the FCA Handbook Perimeter Guidance (PERG) to confirm whether each activity is regulated and whether any exclusion applies. Scope this carefully: listing activities you do not need raises the FCA fee band and the level of scrutiny, while missing an activity means you cannot lawfully carry it on and must later apply to vary your permission.
If your firm manages investments belonging to another person on a discretionary basis, including managing alternative investment funds (AIFs) or UCITS schemes, that is a regulated activity needing its own Part 4A permission. Larger managers are fully authorised alternative investment fund managers; smaller managers below the regime thresholds may use the small AIFM registration regime, and an authorised fund generally needs a depositary appointed. See the snippet below for the statutory basis and scope.
The threshold conditions are the minimum standards the FCA applies to every applicant. The FCA must be satisfied that you meet them, and will continue to meet them, before it grants permission. They cover your legal status, the location of your offices, effective supervision, adequate financial and non-financial resources, suitability and a viable business model. You evidence these conditions through your regulatory business plan, financial projections and governance arrangements.
You apply for permission under Part 4A FSMA through the FCA Connect portal. You will register your firm, complete the question set for your permission profile, and upload your regulatory business plan, financial projections, governance map, compliance arrangements and the Senior Manager applications. The FCA determines a complete application within the statutory period set out in the gateway snippet below; an incomplete application has a longer statutory clock, so submit a full, well-evidenced application the first time.
Book a free pre-application meeting with the FCA before you submit if your business model is novel, you are seeking a complex permission, or you are dual-regulated by the Prudential Regulation Authority. This surfaces issues early and reduces the risk of a returned submission.
The FCA will not authorise a firm that has no approved Senior Managers. Under the Senior Managers and Certification Regime, named individuals must hold the prescribed Senior Management Functions, each with a Statement of Responsibilities, and must be approved by the FCA as fit and proper. You must also operate anti-money laundering systems from day one, including a risk assessment, customer due diligence, a Money Laundering Reporting Officer and suspicious activity reporting. The two snippets below set out what each regime requires.
Authorisation is the start of an ongoing relationship, not the end. From the effective date of your permission you must comply with the FCA Handbook in full, including the Principles for Businesses and the sourcebook for your activity. You must deliver good outcomes for retail customers under the Consumer Duty, pay your annual periodic fee, submit regulatory returns, notify the FCA of material changes, and apply to vary your permission whenever your activities change. The Financial Services and Markets Act 2023 underpins the FCA's post-Brexit rule-making powers that shape these obligations.
The portal for new firm authorisation and Senior Manager approvals.
Guidance on whether your activity is regulated and whether exclusions apply.
Full guidance on each threshold condition the FCA applies.
The primary legislation, including the general prohibition and Part 4A permission regime.