Securing authorisation from the Financial Conduct Authority (FCA) is a major milestone for any firm entering the UK’s financial services market. For asset and wealth managers, this process is rigorous, time-intensive, and requires detailed preparation to meet the FCA’s standards of readiness, willingness, and organisation.

To help firms navigate this journey, fscom has published its FCA authorisation guide for asset and wealth managers, a practical checklist that outlines the regulators expectations, explains the documentation required, and highlights common pitfalls to avoid.

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Understanding what the FCA expects

Before applying for authorisation, firms must demonstrate that they can operate in full compliance with the FCA’s regulatory framework.  The FCA expects firms to be ready, willing, and organised:

  • Ready: Firms must be fully prepared to operate ahead of submission. All documents should be finalised and approved, and key personnel identified and onboarded.
  • Willing: Firms must engage openly and promptly with the FCA throughout the authorisation process.
  • Organised: Firms must have governance structures, controls, and documentation in place to comply from day one of authorisation

This includes adhering to the FCA’s Principles for Business, such as integrity, customer interests, risk management, and  Consumer Duty, which requires firms to deliver good outcomes for retail clients.

 

Preparing a strong application

A successful application hinges on demonstrating that the firm understands both its business model and the regulatory obligations it will be subject to. The guide sets out in detail the key components of a complete application:

  • A comprehensive business plan explaining the firm’s activities, target market, risks, and customer journey.
  • A clearly defined governance structure with identified Senior Management Function (SMF) holders, including the Compliance Officer and MLRO, both of whom must be FCA-approved.
  • Essential supporting documentation, such as an AML policy, Consumer Duty framework, compliance manual, Internal Capital and Risk Assessment (ICARA), and Business Continuity Plan.
  • Financial information covering three years of forecasts and supporting assumptions, showing the firm’s financial resilience.

fscom’s specialists stress the importance of ensuring that applications are both complete and coherent, as incomplete submissions can lead to delays or rejections.

 

Common pitfalls to avoid

The guide highlights several recurring issues identified by the FCA in asset and wealth management applications:

  • Inexperienced senior management: Applicants often propose SMF holders without sufficient industry experience or understanding of the regulatory environment.
  • Weak governance and oversight: Firms sometimes fail to demonstrate effective oversight of outsourced functions, even though accountability remains with the authorised entity.
  • Inadequate conflict of interest management: Asset managers must show how they will identify and manage conflicts arising from control over client assets.
  • Consumer Duty gaps: Applications that do not clearly explain how firms will deliver fair value and good customer outcomes risk rejection.

These issues underline the FCA’s expectation that firms take ownership of their regulatory responsibilities rather than relying on the FCA to identify shortcomings.

 

fscom’s experience with the regulator

Drawing on extensive experience supporting asset and wealth managers through the authorisation process, fscom understands both the practical and procedural challenges firms face.

Our team regularly assists clients with engaging with the FCA  and provides targeted advice on documentation, governance, and prudential requirements. We help firms prepare clear, well-structured submissions that minimise queries and reduce review times, improving the likelihood of a successful outcome.

 

About fscom

fscom Compliance Maturity SpecialistsTM provide regulatory compliance solutions to financial services firms across the UK and Europe. With expertise in payments, asset management, capital markets, banking, and crypto, fscom helps firms benchmark compliance against regulatory requirements and industry peers, giving them a clear understanding of where they stand and how to reach their goals. Our mission is simple: to help firms raise compliance standards so together, we can protect people, prevent financial crime and create a safer society.

This post contains a general summary of advice and is not a complete or definitive statement of the law. Specific advice should be obtained where appropriate.