Table of Contents
- Moving from Appointed Representative to Authorised: First Decisions
- FCA Authorisation Application Requirements
- Building Your FCA Regulatory Business Plan
- Appointed Representative Agreement Termination
- FCA Authorisation Application Timeline
- Common Mistakes When Moving from Appointed Representative to Authorised
- Conclusion: Your Next Steps to Direct Authorisation
- Frequently Asked Questions
Last Updated: 12 October 2026
Moving from Appointed Representative to Authorised: First Decisions
Moving from appointed representative to authorised is the process of ending your firm’s status as an AR under a principal and applying to the FCA for your own Part 4A permission. It gives you full control of your business, but it also moves all regulatory responsibility onto your shoulders. This guide from FCA Authorisation walks through the decisions that matter most.
The shift is bigger than a change of paperwork. As an AR you operate under someone else’s permission. Once authorised, you answer to the FCA directly. That means your own systems, your own capital, and your own regulatory business plan.
Before you start, ask yourself one blunt question: can the business survive without the principal’s cover? We see firms rush this and regret it.
Assess Your Readiness for Direct Authorisation
Readiness comes down to three things: money, people, and systems. If any one is weak, the FCA will find it.
- Capital: Can you meet the financial resources your permission requires?
- People: Do you have a fit and proper senior manager for each key role?
- Systems: Can you monitor compliance, complaints, and training without help?
A common mistake is assuming your existing AR setup is enough. It usually is not. Your principal handled much of the heavy lifting.
Do not resign from your principal before you understand your runway. Losing AR cover too early can leave you unable to trade while the FCA reviews your application.
FCA Authorisation Application Requirements
The FCA authorisation application requirements cover your firm, your people, and your controls. You submit these through the Connect system, and each part must stand on its own.
Expect to provide:
- Company details and ownership structure
- A regulatory business plan
- Financial projections and capital evidence
- Details of senior managers and their fitness
- Compliance and risk frameworks
- IT and outsourcing arrangements
The FCA also assesses your controllers under the change in control rules. If new owners are involved, that adds a separate review.
Supporting keyword: FCA authorisation application requirements. Get this pack right and the rest of the process runs more smoothly.
Building Your FCA Regulatory Business Plan
An FCA regulatory business plan is the document that explains what you will do, how you will do it, and how you will stay compliant. It is not a sales pitch. It is a compliance roadmap.
Cover these areas clearly:
- Your products and target customers
- How you will treat customers fairly
- Your governance and reporting lines
- How you will handle complaints and breaches
- Your financial forecasts for at least three years
Most guides miss this: the FCA reads your plan for gaps, not for polish. A short, honest plan beats a long, vague one.
Write your business plan as if a sceptical reviewer will challenge every claim. Name the risks and show how you will manage them. That tone lands better than optimism.
Appointed Representative Agreement Termination
Appointed representative agreement termination is the formal end of your contract with your principal. It must be handled carefully, because your permissions depend on it.
Check your agreement for:
- Notice periods and exit terms
- Run-off arrangements for existing business
- Handover of client records
- Ongoing obligations after you leave
Timing matters. You do not want a gap between losing AR status and gaining direct authorisation. Many firms overlap the two where the agreement allows.
Tell your clients what is changing and why. Clear communication protects your reputation and reduces complaints later.
FCA Authorisation Application Timeline
The FCA authorisation application timeline depends on how complete your submission is. A clean application moves faster than one with gaps.
The process usually follows these stages:
- Prepare your pack and supporting documents
- Submit through Connect and pay the fee
- Respond to the FCA’s questions
- Complete any further reviews
- Receive your decision
The FCA will come back with questions. That is normal, not a bad sign. How fast you answer often sets the pace.
| Stage | What Happens | Your Focus |
|---|---|---|
| Preparation | Build pack, plan, forecasts | Completeness |
| Submission | Apply via Connect | Accuracy |
| Queries | FCA asks questions | Fast, clear replies |
| Review | Further checks | Evidence |
| Decision | Outcome issued | Next steps |
Common Mistakes When Moving from Appointed Representative to Authorised
The same errors trip up firm after firm. Spot them early and you save months.
- Underestimating capital needs. The FCA checks this closely.
- Thin compliance frameworks. Borrowed AR systems rarely pass.
- Vague business plans. Reviewers want specifics.
- Poor handover from the principal. Missing records cause delays.
- Rushing the resignation. A gap in cover stops you trading.
What most guides miss is the human side. Your senior managers must show they can run a regulated firm, not just a busy one. Prepare them for interviews.
Conclusion: Your Next Steps to Direct Authorisation
The move from appointed representative to authorised rewards preparation over speed. Get your capital, people, and plan right, and the FCA process becomes manageable rather than daunting.
At FCA Authorisation, we have guided firms through this exact transition since 2000. We build your bespoke application pack, manage the project from inception to completion, and work on a fixed project cost basis. Our consultants stay with you when the FCA asks questions, so you are never left to figure it out alone.
Get started with FCA Authorisation and move to direct authorisation with confidence.
Frequently Asked Questions
How do you move from being an appointed representative to being directly authorised?
You apply to the FCA for Part 4A permission, the same route any new firm takes. The process involves preparing a regulatory business plan, completing the application forms, submitting supporting documents, and paying the application fee. You must also notify your principal firm and terminate your appointed representative agreement. The FCA will assess your application and may request further information before granting authorisation.
How long does FCA authorisation take when moving from an appointed representative arrangement?
The FCA’s published service standard for straightforward cases is six months from receipt of a complete application, though complex or incomplete submissions take longer. Moving from an appointed representative arrangement does not automatically speed up the process. Firms that submit a thorough application pack with a clear regulatory business plan typically progress faster because the FCA has fewer follow-up questions.
Can a firm apply for FCA authorisation while it is still an appointed representative?
Yes. You can submit your application while your appointed representative agreement remains in force. This lets you continue regulated activities under your principal’s permission during the assessment period. However, you must tell your principal about the application and plan the termination date carefully so there is no gap in regulatory cover. The FCA expects you to be transparent about your current status.
What documents are needed to apply for direct FCA authorisation?
Core documents include a regulatory business plan, financial projections, details of your senior managers and controlled functions, a compliance and risk framework, and evidence of adequate financial resources. You also need to provide information about your ownership structure, any group entities, and your IT and operational systems. The FCA may request additional documents depending on your regulated activities.