Apply for an FCA Variation of Permission
When is a Variation of Permission required?
A variation of permission (VoP) is required where a regulated firm needs to change, add or remove FCA permissions.
This commonly arises when a firm expands its services, adds new regulated activities, changes regulatory status, or materially alters how existing services are delivered. Examples include adding merchant acquiring, adding AIS or PIS permissions, or removing permissions that are no longer used.
VoP applications are submitted through the FCA application portal and are assessed as a reassessment of the firm rather than a simple administrative update.
What do the FCA Expect?
When assessing a VoP, the FCA expects firms to demonstrate that they remain compliant with the threshold conditions and are operationally ready for the varied 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. 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, including evidence that policies are implemented in practice, safeguarding is functioning correctly, regulatory reporting is accurate and timely, and senior management oversight is effective. Any gaps or divergence are likely to be challenged.
How can The Payment Practice Help?
We support firms through the full VoP process from start to finish. We assess whether a VoP is required and advise on the most appropriate structure and sequencing of changes.
We prepare and update all required documentation, manage submissions through the FCA application portal, and handle ongoing communications and regulatory information requests.
Where safeguarding or capital arrangements are impacted, we help design revised structures and introduce suitable safeguarding account providers.
We also 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 ones.