Building on our series of articles on UK authorisation for early-stage and start-up firms, we have been closely following recent FCA messaging on its approach to authorisation.
In a speech in January 2026, Sheree Howard, FCA Executive Director of Authorisation, reinforced that the regulator is keen to support firms seeking to enter and grow in the UK market. The FCA has emphasised the importance of early engagement and well-prepared applications, alongside the expansion of its pre-authorisation services designed to help firms get their submissions right first time.
The FCA has also committed to improving authorisation timeliness, including through the use of generative AI to better sift and organise unstructured application data. These initiatives are aimed at improving process efficiency, while maintaining robust regulatory decision-making.
In parallel, Ms Howard highlighted the successful launch of the PRA’s Scale-Up Unit, which supports high-growth, dual-regulated firms as they scale in line with regulatory expectations. The FCA has also indicated that a similar model is planned for solo-regulated firms. For international firms, the regulator is exploring more tailored support to facilitate entry and growth in the UK market.
However, notwithstanding this clear pro-growth agenda, the FCA has been unequivocal that standards for authorisation remain unchanged. Firms must continue to meet the statutory threshold conditions in full.
As we have previously highlighted, firms preparing for UK authorisation should pay particular attention to the following:
Provide complete and accurate information
Applications should clearly articulate the firm’s business model, revenue streams and customer impact, supported by appropriate evidence and submitted using the correct FCA templates.
Demonstrate regulatory understanding
Senior management and key individuals must be able to evidence a clear understanding of the firm’s regulatory obligations and how the FCA Handbook applies in practice.
Governance and resourcing
Firms should be ready to demonstrate that they have appropriate governance arrangements, with individuals in the right roles and with sufficient time, expertise and resources to dedicate to those roles.
Proportionate systems and controls
Policies, procedures and controls must be tailored to the firm’s specific business model and risk profile. Generic, off-the-shelf documentation is unlikely to meet regulatory expectations.
The FCA may be open to growth, but it continues to expect firms to be well-prepared, well-governed and able to operate compliantly from day one.
For firms considering UK authorisation, the FCA’s current messaging should be viewed as an opportunity to engage early and thoughtfully, rather than as an indication of a lighter-touch regime.
In practice, firms should expect:
Greater scrutiny of preparedness, not just intent
While the FCA is encouraging applications, it is increasingly focused on whether firms are genuinely “authorisation-ready” at the point of submission. Incomplete, poorly evidenced or internally inconsistent applications are still a primary cause of delays and refusals.
Earlier engagement, but higher expectations
Enhanced pre-application support is helpful, but it also means the regulator will expect firms to have done the foundational work. Early conversations are not a substitute for clear governance, credible financial planning and a coherent regulatory strategy.
Increased focus on senior management capability
The FCA continues to place significant weight on the quality, availability and regulatory understanding of senior individuals. Firms should ensure that key personnel can clearly articulate how regulatory requirements are embedded into day-to-day operations, not just documented in policies.
Proportionality, properly evidenced
Smaller or early-stage firms are not expected to mirror large incumbents, but proportionality must be justified. Firms should be able to explain why their systems and controls are appropriate for their specific business model, growth plans and risk profile.
Realistic timelines and resourcing
Even with process improvements, authorisation remains a resource-intensive exercise. Firms should plan accordingly, allowing sufficient time and internal capacity to respond to FCA queries and information requests during the application process.
Overall, the FCA’s approach reflects a desire to support sustainable growth in the UK market, but only where firms can demonstrate that they are ready to meet regulatory expectations from the outset.
