Variation of Permission
Adding, modifying or removing regulated activities on an existing FCA payment institution or EMI licence.
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What we do
As regulated firms grow and evolve, they frequently need to change their regulatory permissions: adding new activities, extending to new client types, or removing permissions they no longer need.
A variation of permission (VOP) application is submitted to the regulator to request these changes. The FCA assesses VOP applications to ensure the firm has adequate resources, systems, and controls for proposed new activities.
Our VOP service manages the entire process, from assessing what permissions are needed through to submission and approval. We ensure your application is comprehensive and positions your firm for the fastest possible approval.
Permission Mapping
We identify exactly which permissions need to be added, varied, or removed.
Gap Analysis
We assess your current arrangements against requirements for the proposed new permissions.
Application Preparation
We prepare the VOP application with all supporting documentation.
Submission & Management
We submit and manage the regulatory review process through to approval.
What's Included
Permission Analysis
Detailed mapping of required permission changes against your business requirements.
VOP Application
Complete variation of permission application prepared for regulatory submission.
Updated Business Plan
Revised business plan reflecting the proposed new or varied activities.
Updated Compliance Framework
Amended policies and procedures covering the new regulated activities.
Capital Assessment
Updated capital adequacy assessment reflecting the new permission scope.
Regulator Liaison
Management of all regulator communications during the VOP assessment period.
Who this service is for
Firm types
- - Payment institutions adding new services
- - EMIs extending their product range
- - Firms adding PIS or AIS services
- - Regulated firms rationalising permissions
Situations & Triggers
- - Launching payment initiation or account information services
- - Adding acquiring or currency conversion activities
- - Extending to new customer segments
- - Removing unused permissions to reduce regulatory burden
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
Variation of Permission: FCA Process, Requirements and Timelines
When an FCA-authorised firm needs a variation of permission, what to submit through Connect, the statutory deadlines for a decision and how to avoid the common delays.
Removing FCA Permissions: Voluntary Variation and Cancellation of Authorisation
How an FCA-regulated firm removes some permissions or cancels its authorisation, the wind-down plan the FCA expects, what happens to customer funds and the decision timeline.
FCA Permissions Review: Aligning Authorisation to Actual Business Activity
Check that your FCA permissions match what the business actually does. Perimeter analysis, variation of permission and its statutory timing, requirements and limitations, unused permissions and cancellation explained.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently asked questions
A formal application to your regulator to change your authorised activities: adding new permissions, extending scope, or removing permissions you no longer need.
FCA VOPs typically take 6 to 8 weeks for straightforward variations and up to 6 months for complex additions of new regulated activities.
Common triggers include launching new payment services, adding PIS or AIS, extending to new customer types, or adding acquiring services.
Generally yes, because the firm is already authorised. However, adding significantly new activities may require comparable assessment.
The FCA wants to see financial resources, governance, systems, controls, and expertise to undertake the proposed new activities safely.
No. You must not undertake the new activity until the VOP has been approved. Operating without appropriate permissions is a regulatory breach.
Yes. Removing unused permissions can simplify your regulatory obligations and reduce compliance costs. We manage the surrender process.
No. Your existing permissions remain in place during the VOP process. The variation only affects the specific permissions being added, varied, or removed.