FCA Authorisation Readiness Checklist

FCA authorisation preparation is not only a document production exercise. A firm has to show that its business model, governance, safeguarding arrangements, systems, controls, people, and financial resources can operate in a regulated environment. The strongest applications are usually those where the evidence already behaves like an operating system, not a collection of files assembled at the end.

For payment and e-money firms, readiness starts with perimeter clarity. The applicant needs to understand which regulated activities it will perform, which permissions or registration route apply, how money moves through the business, where customer funds sit, which outsourced providers are critical, and who is accountable for each control. If that logic is unclear internally, it will be hard to explain externally.

The governance file should answer a simple question: who is allowed to decide what, and where is the evidence that they have done so? Board minutes, committee terms, senior manager responsibilities, policy approvals, risk acceptance decisions, and escalation records should connect to the firm’s actual operating model. Policies that say the right things but do not map to named owners, controls, and evidence are weak readiness signals.

Financial readiness is equally important. Applicants should be able to explain capital, liquidity, wind-down assumptions, revenue logic, cost completeness, safeguarding treatment, outsourcing costs, and stress scenarios. The issue is not only whether a spreadsheet balances; it is whether the assumptions are coherent with the regulated activities being proposed.

Safeguarding, where relevant, needs particular attention. The FCA expects payment and e-money firms to understand when the safeguarding obligation starts, how relevant funds are identified, how reconciliations work, how third parties are selected and reviewed, and how records would support an orderly return of funds if the firm failed.

A useful readiness test is to simulate a case officer challenge before submission. Ask whether every policy statement has an owner, every control has evidence, every financial assumption has a rationale, every outsourcing dependency has governance, and every board decision can be reconstructed. Gaps found before submission are cheaper than gaps found during review.

RegNexus RAV is designed for this preparation stage. It helps firms structure policy evidence, test authorisation logic, challenge inconsistencies, and assemble a more defensible operating record before the application is exposed to regulatory scrutiny.