Apply for an FCA Variation of Permission
When is a Variation of Permission required?
A FCA Variation of Permission (VoP) is necessary when a regulated firm needs to change, add, or remove FCA permissions. This situation often arises when a firm expands its services, adds new regulated activities, changes its regulatory status, or significantly alters the delivery of existing services. Examples include adding merchant acquiring permissions, introducing AIS or PIS permissions, or removing permissions that are no longer utilized. VoP applications are submitted via the FCA application portal and are evaluated as a reassessment of the firm rather than merely an administrative update, requiring adequate regulatory support.
What do the FCA Expect?
When assessing a VoP, the FCA expects firms to demonstrate compliance with the threshold conditions and ensure they are operationally ready for the varied permissions, including FCA permissions. The FCA will typically review updated information on the business model, programme of operations, customer journeys, transaction and fund flows, governance and management arrangements, financial resources and forecasts. Additionally, AML, fraud, and safeguarding frameworks are reassessed where risk or scale is increasing, alongside operational resilience, IT security, and outsourcing controls. A key focus is verifying that the firm has been operating in line with the commitments made in its original application for FCA Variation of Permission. This includes providing evidence that policies are implemented in practice, safeguarding functions correctly, regulatory reporting is accurate and timely, and senior management oversight is effective. Any gaps or divergence are likely to be challenged, and firms may require regulatory support to address these issues.
How can The Payment Practice Help?
We support firms through the complete FCA Variation of Permission (VoP) process from start to finish. We assess whether FCA permissions are required and advise on the most appropriate structure and sequencing of changes.
We prepare and update all necessary documentation, manage submissions through the FCA application portal, and handle ongoing communications and regulatory information requests.
When safeguarding or capital arrangements are affected, we assist in designing revised structures and introduce suitable safeguarding account providers.
Additionally, we prepare directors and senior managers for FCA meetings or interviews, ensuring they can clearly demonstrate both operational readiness for the new permissions and ongoing compliance with existing regulatory requirements.