When FCA Authorisation Needs a Variation of Permission
Changing regulated activity when you are already authorized requires a Variation of Permission (VoP) not a new application for FCA authorization.
Adding a New Regulated Activity
For example, a firm of insurance distributors might wish to carry out credit broking. That is a regulated activity but not one covered by their current permission. They will need a VoP before they can start to carry out the new activity.
Removing or Restricting a Permission
It is not uncommon for a firm to want to restrict part or all of its activities, for example due to a strategic change or for compliance reasons. A VoP is also required for the surrender or restriction of permissions.
Changing a Financial Limit
As with activity, some permissions have financial limits. Even if it is apparently an administrative change (e.g. to increase a lending amount) a Variations of Permission application is required, not a FCA update.
Expanding into a New Product Type
A change to offer mortgage, consumer credit or investment products where you are currently restricted from doing so will also require a Variation of Permission, as this will be outside of your current FCA authorization.
Submitting Your VoP via Connect
A VoP application is submitted through the FCA’s Connect system, with applicants required to provide a valid business reason for the proposed change(s), adequate systems and processes to support the change(s), and supporting documentation as required by the FCA’s guidance on variation of permission compared with application for permission.
This will take several months to come to a decision, so apply early to ensure that the start date of your planned launch is not delayed.
