Table of Contents
- What the FCA Expects From Your Business Plan
- FCA Authorisation Business Plan Requirements
- Step 1: Define Your Regulatory Scope and Permissions
- Step 2: Build Your FCA Business Plan Financial Projections
- Step 3: Using an FCA Regulatory Business Plan Template
- Step 4: What a Strong FCA Business Plan Example Looks Like
- Common Mistakes to Avoid in Your FCA Business Plan
- Conclusion
- Frequently Asked Questions
Last Updated: 16 October 2026
What the FCA Expects From Your Business Plan
A business plan for FCA authorisation is a regulatory document, not a pitch deck. The regulator reads it to test whether your firm can meet its threshold conditions, not to admire your growth story. Learning how to prepare an FCA business plan means answering the same questions an examiner will ask, in the same order, with evidence.
Every year, firms approach us at FCA Authorisation with polished investor decks and almost nothing the FCA can actually assess. That gap is where applications stall.
The FCA expects your plan to cover six things: your business model, your customers, your finances, your controls, your people, and your exit. Miss any of them and you invite a follow-up question, which adds weeks to your timeline. Below, we break the process into seven steps, from defining your permissions to avoiding the mistakes that sink otherwise strong applications.
The Threshold Conditions Behind Every Question
The FCA’s threshold conditions are the legal tests your firm must pass to be authorised (FCA Handbook). They cover location of offices, effective supervision, appropriate resources, suitability, and business model. Every question in the application form traces back to one of them.
This matters because it changes how you write. A financial projection is not there to impress. It is there to prove you have appropriate resources. A CV is not a biography. It is evidence of suitability.
Read the threshold conditions before you write a single word. Then map each section of your plan to the condition it satisfies. That mapping is the backbone of a strong submission.
FCA Authorisation Business Plan Requirements
The FCA authorisation business plan requirements come down to a set of core documents. The FCA publishes its expectations in the FCA authorisation application guidance, and the depth expected scales with the risk of your proposed activities.
Your pack will typically need:
- A clear description of the regulated activities you intend to carry out
- A three-year financial forecast with assumptions stated
- Details of your governance, systems and controls
- Regulatory history for the firm and its controllers
- Senior manager and certification regime mapping
- A wind-down plan showing an orderly exit
A payments firm and an investment firm will not submit the same document. A firm holding client money will face deeper questions on safeguarding. Match your plan to your actual permissions. Generic submissions get generic scrutiny, and that is the slowest route through the process.
Step 1: Define Your Regulatory Scope and Permissions
Start with scope, because everything else depends on it. Write down every regulated activity you intend to carry out, and the specific permission you need for each one.
Be precise. “Financial advice” is not a permission. “Advising on investments” is. Overclaiming permissions you do not need adds cost and supervision you will not use. Underclaiming means you cannot legally launch the product you built.
A common mistake is copying a competitor’s permission set. Their model is not yours. If you plan to hold client money, deal as principal, or operate a payment service, say so from the start. Varying permissions later is possible, but it is a second application and a second wait.
Listing permissions “just in case” is one of the most common errors we see. It widens your regulatory footprint, increases your capital requirement, and gives the FCA more to question. Claim only what your business model genuinely needs.
Step 2: Build Your FCA Business Plan Financial Projections
Your FCA business plan financial projections must show three years of forecasts, and they must be defensible. The FCA is not testing whether you can predict the future. It is testing whether you understand your own economics.
State your assumptions plainly. Customer numbers, average revenue per customer, cost base, and the capital you hold against each risk. If you project a loss in year one, show how you fund it. If you project rapid growth, show what breaks if it does not arrive.
Two tests trip up most applicants.
Stress Testing and the Wind-Down Scenario
Stress testing asks what happens when things go wrong. Model a downside: slower growth, higher costs, a key client lost. Then show you still meet your capital requirement.
The wind-down scenario is the one applicants most often skip. It asks how you would close the firm in an orderly way without harming customers. It feels morbid. It is also mandatory for many permission types.
Answer both in plain numbers, not narrative. A short table beats three paragraphs of reassurance.
| Scenario | What Changes | What It Proves |
|---|---|---|
| Base case | Steady growth as planned | Viable model |
| Downside | Slower revenue, higher costs | Capital buffer holds |
| Wind-down | Ordered closure | Customers protected |
Step 3: Using an FCA Regulatory Business Plan Template
An FCA regulatory business plan template saves time, but only if you use it as a skeleton. Templates give you the sections and the questions. They cannot give you your answers.
Where templates help:
- They list every section the FCA expects, so nothing is missed
- They prompt the financial and governance detail examiners look for
- They keep the structure consistent with what reviewers see daily
Where they hurt: pasting a competitor’s content into a template is obvious and damaging. Reviewers read hundreds of these. A document that does not match your actual model stands out for the wrong reasons. Use the template for structure, then fill every section with your own specifics.
Step 4: What a Strong FCA Business Plan Example Looks Like
A strong FCA business plan example reads like a firm that already knows how it operates. It is specific, internally consistent, and free of contradictions.
Picture a payments start-up seeking authorisation. Its plan names the exact payment services it will offer, shows the safeguarding method for client funds, lists two named senior managers with relevant history, and projects a realistic path to break-even. Every number ties to an assumption stated earlier.
Now picture a weak version of the same plan. It describes “innovative financial solutions”, promises aggressive growth, and leaves the safeguarding section vague. The first plan gets questions it can answer. The second gets questions it cannot.
The difference is not length. It is precision. A short plan that answers every threshold condition beats a long plan that dodges them.
Common Mistakes to Avoid in Your FCA Business Plan
The mistakes that delay applications are predictable, and that is good news. Most are avoidable before you submit.
- Vague business descriptions that leave the reviewer guessing at your model
- Financial projections with no stated assumptions behind them
- Missing or thin wind-down planning
- Senior managers named without evidence of relevant experience
- Internal contradictions between the narrative and the numbers
- Copying another firm’s permission set or content
Each one invites a follow-up question. Follow-up questions add weeks. A submission that answers everything first time moves faster, and that is the whole point of preparing carefully.
If you have been rejected before, the fix is rarely a new template. It is finding the specific gap that caused the rejection and closing it with evidence.
Conclusion
Getting an FCA business plan right is demanding, and the cost of getting it wrong is measured in months, not days. Most delays trace back to the same handful of gaps: unclear scope, unsupported projections, and thin governance detail. At FCA Authorisation, we have prepared bespoke application packs since 2000, working on a fixed project cost basis with project management from inception to completion. Our consultants build the plan around your actual model rather than a one-size-fits-all template. Get started with FCA Authorisation and move through the process with a plan built to pass scrutiny.
Frequently Asked Questions
What should an FCA business plan include?
An FCA business plan should cover your regulatory scope and permissions, ownership and control structure, senior management responsibilities, three-year financial projections, resourcing and outsourcing arrangements, systems and controls, and a wind-down plan. Each section must show how your firm meets the FCA’s threshold conditions. The FCA also expects evidence that you understand the risks in your specific sector, so generic statements carry little weight. Treat it as a regulatory document, not a sales pitch.
Does the FCA provide a business plan template?
No, the FCA does not publish a standard template. It sets out expectations in the Approach Document and the relevant sector guidance, leaving firms to structure their own submission. Many applicants use an FCA regulatory business plan template as a starting framework, then tailor it to their permissions and business model. A template is a useful checklist, but the FCA assesses the substance behind each answer, so avoid copying generic wording.
How detailed should the FCA business plan financial projections be?
Detailed enough to show how your firm will remain viable and meet its regulatory capital requirements. Provide monthly figures for the first year and annual figures for the following two years, including profit and loss, balance sheet and cash flow. Set out your assumptions clearly and include a downside scenario showing how the firm would cope with slower growth. The FCA looks for realistic numbers that match your stated business model.
How long does it take to prepare an FCA business plan?
Most firms need several weeks to draft a credible plan, depending on the complexity of their permissions and how quickly they can confirm their financial forecasts. Bespoke or cross-border applications take longer because they raise more questions about control and resourcing. The FCA’s own review clock runs separately once you submit, so a rushed plan often leads to follow-up questions that delay the whole application. Start early and build in time for internal review.