As global financial markets continue to evolve, the UK remains a key jurisdiction for wholesale financial services. However, for international firms seeking to serve professional clients or eligible counterparties in the UK, the process of obtaining authorisation from the Financial Conduct Authority (FCA) is a critical yet complex one. It requires maturity, clarity and strategic planning.To help international firms confidently manage the UK’s regulatory landscape, the FCA has published guidance tailored to wholesale markets firms operating from overseas. Below, fscom’s Capital Markets specialist, Stacey Copper summarises the key points and explains how fscom can support your journey from application to authorisation and beyond. 

 

A changing regulatory landscape for global wholesale firms

The FCA has recently published guidance specifically for international firms seeking to operate in the UK wholesale markets, targeting firms engaged in investment banking, broking, and trading activity, typically serving institutional clients.

Key drivers for this guidance include:

  • Ensuring that firms seeking UK access are appropriately supervised and well-governed
  • Preventing “brass plate” authorisations with minimal real presence in the UK
  • Clarifying how FSMA and SMCR obligations apply to UK branches or subsidiaries of international firms

This represents a more demanding authorisation environment where UK regulators want evidence of meaningful local oversight, operational readiness, and individual accountability.

 

What does the FCA expect from international wholesale firms seeking UK authorisation?

The answer is clear: overseas firms must demonstrate substance, clarity, and readiness.

Let’s explore what that means in practice:

Substance in the UK: real presence, not just a nameplate

One of the most critical FCA expectations is genuine operational presence in the UK. The regulator is unlikely to authorise firms that appear to be “brass plate” operations i.e. minimal staff, outsourced governance, or decision-making retained overseas.

Firms must show:

  • A credible and staffed UK office
  • UK-based governance structures with decision-making power
  • Senior Managers under SM&CR who are accountable for UK operations

Firms should avoid placing key oversight roles overseas unless there’s a strong rationale and robust local delegation in place.

A robust regulatory business plan: UK focused and risk aware

Your regulatory business plan is a cornerstone of the FCA application and it must go beyond basic compliance. It must:

  • Be tailored to your UK strategy and risk profile
  • Clearly outline the services you’ll provide, your target client base, and operational model
  • Show understanding of the UK regulatory perimeter and relevant permissions

Include analysis of how you will manage key risks, maintain financial resources, and supervise staff.

Clear understanding of permissions and regulatory boundaries

Firms must accurately map their proposed UK activities to the appropriate FCA permissions under the FSMA Part 4A regime.

Common mistakes include:

  • Overstating what permissions are required (leading to unnecessary scrutiny)
  • Misunderstanding what falls under UK regulatory scope
  • Failing to identify where permissions are not needed but conduct obligations still apply

Engaging with the FCA early via a pre-application meeting is highly recommended for firms with novel, complex, or dual-supervised models.

Senior management and SMCR compliance

The FCA expects senior managers to:

  • Be physically located in the UK (or justify otherwise)
  • Fully understand their individual responsibilities
  • Operate within a clear governance structure

You will need to:

  • Assign SMFs appropriately (e.g. SMF3 Executive Director, SMF16 Compliance Oversight)
  • Define prescribed responsibilities clearly
  • Submit statements of responsibilities and management responsibilities maps

Consider training new UK-based SMFs early in the application process so they are fully FCA-ready.

 

Common challenges for international applicants 

Firms often underestimate the level of compliance maturity required. Common challenges include:

  • Navigating dual supervision where UK operations are heavily dependent on overseas group entities 
  • Demonstrating sufficient local governance and risk oversight 
  • Addressing regulatory equivalence concerns between the UK and your home jurisdiction 
  • Understanding prudential rules under the IFPR/MiFIDPRU regimes 

 

How fscom can help

At fscom, we specialise in compliance maturity. We help wholesale firms benchmark their regulatory readiness, strengthen governance frameworks and align with FCA expectations from day one. We have extensive experience supporting international wholesale firms through the FCA authorisation journey, from early-stage strategy through to post-approval compliance.

We provide:

  • Pre application strategic advice tailored to your operating model
  • End-to-end FCA authorisation support
  • Tailored regulatory business plans
  • SMCR framework design and training
  • UK governance structuring
  • Ongoing compliance advisory post authorisation

Whether you’re setting up a UK branch or a new subsidiary, our team works to ensure your firm is regulator ready while preserving your global strategy.

 

Conclusion: authorisation is just the start

Achieving FCA authorisation signals the start of your UK growth journey. Firms that invest in proper preparation, early FCA engagement, and strong local infrastructure are far more likely to gain authorisation, and to build sustainable UK operations.

To discuss your authorisation project or benchmark your readiness, get in touch with our Capital Markets compliance team today or to get an instant view of where you stand, take our Compliance Maturity Self-Assessment now.

 

This blog contains a summary of FCA guidance and is not a substitute for tailored legal or regulatory advice. Please consult your fscom adviser before acting on any of the above.