For e-money and payments firms in the UK, securing FCA authorisation is more than a regulatory requirement — it’s a catalyst for growth and more control. For those currently operating as an Agent, authorisation reduces reliance on a Principal and the costs that come with it. It can also open doors commercially, as major card networks and payment scheme sponsors often prefer to work with firms that hold their own licence.
However, preparing an application and navigating the FCA’s assessment process is often more complex and time-consuming than firms anticipate.
The FCA notes that many applications are rejected for incompleteness, or withdrawn or refused because they fail to demonstrate that the applicant meets the standards for authorisation. In our experience, the firms that invest in producing a complete, clear, and well-structured application not only improve their chances of success but also help to streamline the FCA’s assessment process.
This article highlights what the FCA looks for, common mistakes to avoid, and good practices that can set your application up for success.
The application process at a glance
Applications are made under the Payment Services Regulations (PSRs) or the Electronic Money Regulations (EMRs) are handled by the FCA’s Payments and Digital Assets Authorisation team through the following process:
Pre-application support (PASS): optional meeting with a Case Officer via Connect to discuss plans and ask questions prior to applying.
Application submission
Initial review and feedback
Assessment and interviews: including scrutiny of governance, safeguarding, AML and operational resilience.
Feedback and outcome.
The main questions that the process seeks to answer are:
What does the applicant want to do?
Who will be involved in managing the firm?
How will the firm run its business?
Timelines and outcomes
Although the FCA is obliged to determine complete e-money or payments authorisation applications within three months, this period starts once an application has been deemed complete and is subject to ‘clock stopping’ if the FCA requests additional information. In practice, recent applications have ranged from 13 to 27 weeks from submission to decision.
The FCA recently announced new targets for faster authorisations, but the target for complete e-money and payments authorisations is unchanged.
Possible outcomes include:
Authorisation or registration granted
The applicant receives a letter confirming the scope of their approval, when it starts and any requirements or limitations which will be applicable
The firm is added automatically to the Financial Services Register
The FCA may invite the firm to be part of Early and High Growth Oversight.
Rejection if minimum information is missing.
Withdrawal by the applicant if not ready to proceed.
Refusal if FCA standards are not met.
ℹ️ Although between 15-20% of submitted applications result in authorisation, once rejected applications are stripped out, the approval rate rises to approximately 55%.
To provide applicants with more confidence to progress the build-out of their business, the FCA intends to make greater use of ‘minded to’ letters; these letters indicate the FCA’s intent to grant authorisation or registration, subject to the applicant firm fulfilling certain conditions (e.g. injection of qualifying capital, establishment of safeguarding measures, finalisation of contracts with partners).
FCA authorisation: Good application practices for payments and e-money firms
Successful applications tend to share several traits:
1. Preparation and Engagement
Use the FCA’s Pre-Application Support Service (PASS).
Engage early with safeguarding banks, auditors and key partners.
Consider independent advice — but ensure your management team, not just advisors, can speak confidently about the business.
2. Governance and Leadership
Appoint key individuals (including MLRO and SMF holders) before applying.
Demonstrate the “UK mind and management” with senior decision-makers based in the UK.
Evidence independent challenge through non-executives or external reviewers.
3. Documentation and Evidence
Submit clear, complete, internally reviewed documents (business plan, risk assessments, financials, policies).
Show how compliance and risk frameworks are already in place or tested.
Keep information consistent across business plan, policies and financials.
4. Ongoing Readiness
Update the FCA on material changes during the assessment period.
Demonstrate awareness of evolving regulatory requirements and expectations.
Respond promptly and fully to any FCA queries.
Common mistakes in FCA payment and e-money licence applications
On the other hand, rejection, delay or refusal can occur due to:
Incomplete or inconsistent submissions (unsigned policies, gaps in financials, outdated information).
Over-reliance on advisors without management buy-in.
Weak governance (unclear responsibilities, reliance on short-term contractors, lack of UK presence).
Superficial risk assessments that don’t explain inherent risks or why chosen controls are effective.
Failure to stress test financial assumptions (e.g. dependence on future fundraising).
Premature marketing of products/services before authorisation is granted.
Each of these signals to the FCA that a firm may not be ready, willing, and organised to operate compliantly.
Final thoughts
The FCA authorisation process is not just paperwork — it is a critical business growth enabler that requires investment of time, expertise, and resources. Firms that approach the process strategically, with robust governance and evidence of operational readiness, are best placed to secure approval without costly delays.
At FINTRAIL, we’re able to support payments and e-money firms of all sizes through this journey. Whether it is refining regulatory business plans, undertaking risk assessments, reviewing policies, or testing compliance frameworks, we help applicants demonstrate their readiness for authorisation.
👉 If your firm is preparing to apply for authorisation, contact us to explore how our regulatory compliance services can support your application.