One of the most common questions from firms seeking FCA authorisation is: how long will it actually take? The short answer: the FCA must decide a complete payment institution or EMI application within three months, and a complete FSMA application within six months. Every application must be decided within 12 months, complete or not. The FCA reports that 99% of applications are decided within these statutory deadlines. This article sets out the deadlines, the FCA's 2026 targets and what makes an application move quickly.
Statutory Deadlines vs Reality
The FCA has statutory deadlines for deciding applications:
| Application type | Complete application | Incomplete application | FCA target from January 2026 |
|---|---|---|---|
| Authorised payment institution (PSRs 2017, regulation 9) | 3 months | 12 months | 3 months complete; 10 months incomplete |
| Small payment institution registration (regulation 15 applies the same limits) | 3 months | 12 months | 3 months complete; 10 months incomplete |
| E-money institution (EMRs 2011, regulation 9) | 3 months | 12 months | 3 months complete; 10 months incomplete |
| FSMA firms, such as consumer credit or investment firms | 6 months | 12 months | Proposed statutory 4 months complete; 10 months incomplete |
| Cryptoasset firms (new FSMA regime) | 6 months | 12 months | Window applications decided before 25 October 2027 |
An application is complete when the FCA has all the information it needs to decide it. The FCA can decide an incomplete application, but must decide every application within 12 months of receipt. For senior manager approvals, the FCA aims to decide at least half within 35 days.
In practice, the clock that matters is the one that starts when the application is complete. Information requests, where the FCA asks for more detail or clarification, are part of every assessment. Answering them fully and quickly keeps the application on the FCA's own timetable.
Realistic Timelines by Firm Type
Authorised Payment Institutions (APIs). The FCA targets a decision within three months of a complete application. Applications with a confirmed safeguarding bank, tailored policies and credible financial projections reach completeness quickly. See our guide to API authorisation.
Small Payment Institutions (SPIs). The same three-month and 12-month limits apply to registration. The assessment is lighter, but the FCA still reviews AML controls and governance in full.
Authorised Electronic Money Institutions (AEMIs). The statutory limits and the FCA's targets match those for APIs. EMI applications carry more evidence on safeguarding, capital and wind-down planning, so preparation takes longer before submission. See our guide to EMI authorisation.
Cryptoasset firms (FSMA regime). The FCA's application window runs from 30 September 2026 to 28 February 2027. The FCA aims to decide all applications made in the window before the regime starts on 25 October 2027. Applications made after the window will not be expedited. See our guide to UK cryptoasset authorisation.
FSMA firms. Consumer credit, investment, insurance and mortgage firms apply under FSMA, with statutory deadlines of six months for a complete application and 12 months overall. HM Treasury confirmed on 12 May 2026 that these will fall to four and 10 months once the legislation passes. See our guide to FCA consumer credit authorisation.
What Drives Timeline Variation
The single biggest determinant of authorisation timeline is the quality and completeness of the application at submission. A complete application starts the shorter statutory clock, and each well-answered information request keeps it moving.
Common triggers for extensive information requests include: - Generic AML policies not tailored to the firm's specific business model - Unrealistic financial projections without credible supporting evidence - Incomplete Individual Questionnaires for key personnel - Vague safeguarding arrangements without confirmed banking relationships - Inadequate explanation of the firm's business model and target market
How to Accelerate the Process
- Invest in application quality. The highest-return investment is application preparation. A well-drafted, comprehensive application that anticipates FCA questions will progress significantly faster.
- Tailor everything. Generic template documents are the single most common cause of information requests. Every document must be tailored to your specific business model.
- Confirm arrangements before submission. Safeguarding accounts, banking relationships, key personnel appointments and premises should all be confirmed before application submission.
- Respond to information requests promptly and completely. Each incomplete or delayed response adds weeks to the timeline.
- Consider pre-application engagement. For innovative business models, the FCA's Innovation team can provide pre-application guidance that helps firms prepare more effective applications.
The FCA's Growth Agenda
The FCA set faster targets in July 2025 and has measured performance against them since January 2026. Payments and e-money applications now have a 10-month target for incomplete applications, down from 12. HM Treasury confirmed on 12 May 2026 that FSMA statutory deadlines will fall from six to four months for complete applications and from 12 to 10 months for incomplete ones, through amendments to FSMA. Until that legislation passes, the current deadlines apply.
Regulatory Counsel manages FCA authorisation applications from initial planning through to approval, with deep experience of the assessment process and information request management. Contact us for a written proposal.
Frequently asked questions
The FCA must decide within three months of a complete application and 12 months overall, and it targets 10 months for incomplete applications. The main variable is how quickly the application becomes complete.
Incomplete applications, particularly generic AML policies, unsupported financial projections, missing safeguarding arrangements and incomplete information on key individuals. Each gap leads to an information request.
Yes, in part. Since January 2026 the FCA targets 10 months, not 12, for incomplete payments and e-money applications, and FSMA statutory deadlines are due to fall to four and 10 months. Application quality remains the biggest factor.
For innovative business models, pre-application engagement with the FCA's Innovation or Authorisations team can be valuable for setting expectations and refining the application approach.
The FCA must decide within three months of a complete application and within 12 months overall (regulation 9 of the EMRs 2011). Since January 2026 it targets 10 months for incomplete applications.
The FCA aims to decide every application made between 30 September 2026 and 28 February 2027 before the regime starts on 25 October 2027. Later applications are not expedited.
Definitive guides on this topic
The permanent reference pages this article relates to.