How to become a directly authorised financial adviser

Key points

  • A directly authorised advice firm needs its own FCA Part 4A permission, applied for through Connect, with a Category 4 fee of £2,820 for most financial advisers.
  • Most advice firms are personal investment firms under IPRU(INV) 13. Capital is the highest of £20,000, 5% or 10% of annual income, and £500,000 if the firm provides targeted support.
  • PII must meet IPRU(INV) 13.1: at least £500,000 per claim and in aggregate for smaller firms that are not IDD insurance intermediaries, with an excess of no more than £5,000.
  • Senior managers need FCA approval under SM&CR. Advisers need an appropriate qualification and a current Statement of Professional Standing.
  • The FCA has 6 months to decide a complete application and 12 months for any application. The Government plans to cut these to 4 and 10 months.
On this page

To become a directly authorised financial adviser, your firm applies to the FCA for its own Part 4A permission through Connect, pays the application fee (Category 4, £2,820, for most financial advisers), and shows it can meet the threshold conditions from day one. For a typical advice firm that means capital of at least £20,000, professional indemnity insurance (PII) that meets IPRU(INV) 13, approved senior managers and a credible business plan. The FCA must decide a complete application within 6 months and any application within 12 months, and the Government has confirmed plans to cut those limits to 4 and 10 months.

This guide covers the route for an advice firm that wants its own permission rather than working under a network or principal. It sets out the permissions, the capital and PII rules as they stand in the FCA Handbook on 15 November 2026, the people requirements, what goes in the application and what changes once you are authorised.

Directly authorised or appointed representative: the first decision

A directly authorised (DA) firm holds its own FCA permission and is responsible for its own compliance. An appointed representative (AR) works under a principal firm that has accepted regulatory responsibility for it in writing. Many advisers start as an AR and move to DA status when they want control of their investment proposition, platform and provider panel, their own brand, or their own compliance standards.

Neither route is better in itself. DA status brings control and higher fixed costs: capital, PII, FCA fees and levies, and your own compliance function. Our guide to directly authorised versus appointed representative status compares the two in detail, sector by sector.

Which FCA permissions an advice firm needs

Permission is granted activity by activity and product by product. Apply for what your business plan supports now and in the next 12 months, not for everything you might do one day. Unused permissions raise questions and can increase fees.

ActivityWhat it coversWho typically needs it
Advising on investments (except P2P agreements)Personal recommendations on pensions, ISAs, unit trusts, life policies and other investmentsEvery advice firm
Arranging (bringing about) deals in investmentsTaking the steps that bring about a transaction for the clientMost advice firms
Making arrangements with a view to transactions in investmentsIntroducing clients to platforms and providers, submitting applicationsMost advice firms
Pension transfers and opt-outsAdvice on giving up safeguarded benefits, such as a defined benefit transferOnly firms with a qualified pension transfer specialist
Insurance distribution (life and protection)Advising on and arranging life cover, income protection and critical illnessFirms that also write protection
Home finance mediationAdvising on and arranging regulated mortgagesFirms that also give mortgage advice
Managing investmentsDiscretionary management of client portfoliosOnly firms running their own discretionary service

Most new advice firms also apply with a requirement that they do not hold or control client money. That keeps the firm out of the client money rules in CASS and lowers its capital requirement, as the next section shows. Client fees are then paid to the firm for its own account, and client money for investment goes direct to providers and platforms.

Personal investment firm or MiFID investment firm

Most independent and restricted advice firms are personal investment firms in the FCA's terms. The FCA Glossary defines a personal investment firm broadly as a firm whose main income comes from advising on or arranging packaged products, or managing investments for retail clients. These firms use the prudential rules in IPRU(INV) 13, not the Investment Firms Prudential Regime (IFPR).

A firm that offers wider MiFID services, such as holding client assets or executing orders, may instead be a MIFIDPRU investment firm, with a permanent minimum capital of at least £75,000. Our FCA authorisation guide for investment firms covers that route. Getting the classification right matters, because it decides your capital, your reporting and how the FCA reads your application.

Capital: the £20,000 rule and the percentage of income

Under IPRU(INV) 13.13.2R a personal investment firm's capital resources requirement is the highest of three amounts: £20,000; a percentage of annual income that depends on the firm's category; and, for a firm with permission to provide targeted support, £500,000.

Firm categoryWhat it meansPercentage of annual income
Category B1Permission includes dealing in investments as principal10%
Category B2Not dealing as principal, and not barred from holding client money or custody assets10%
Category B3 managing life policy portfoliosBarred from holding client money, and managing portfolios containing only life policies10%
Category B3, all othersBarred from holding client money or custody assets, with advising, arranging and similar permissions only5%

A typical new advice firm with a no client money requirement is a category B3 firm. With annual income of £300,000 its requirement is the higher of £20,000 and 5% of £300,000 (£15,000), so £20,000. The requirement only exceeds £20,000 once annual income passes £400,000.

Firms that also give mortgage or insurance advice add part of the MIPRU 4.2 requirement on top of the percentage, under IPRU(INV) 13.13.3R. The FCA's own example is a category B3 firm with £300,000 of investment income and £100,000 of mortgage income: 5% of £300,000 plus 2.5% of £100,000 gives £17,500, so the £20,000 floor still applies.

The firm must also be able to meet its liabilities as they fall due at all times (IPRU(INV) 13.1.4R). Capital is calculated from items such as paid-up share capital and audited retained profits, under IPRU(INV) 13.15. In practice the FCA will want to see the capital in the firm's bank account, plus a buffer, and financial projections showing it stays above the requirement through a weak first year.

Professional indemnity insurance: the minimum cover

PII is often the hardest part of becoming directly authorised. IPRU(INV) 13.1 sets minimum limits of indemnity per year, and the cover must be in place from the day the permission takes effect.

FirmSingle claimAggregate
Not an IDD insurance intermediary, relevant income up to £3 million£500,000£500,000
Not an IDD insurance intermediary, relevant income over £3 million£650,000£1,000,000
IDD insurance intermediary (for example, also advising on life or protection policies)EUR 1,300,380EUR 1,924,560
Relevant income over £10 millionAs aboveHigher aggregate from the IPRU(INV) 13.1.19R table, starting at £2,000,000

The policy must also:

  • cover claims arising from the acts of the firm, its employees and its appointed representatives
  • give full retroactive cover for past business, and cover Ombudsman awards
  • not exclude any type of business the firm has done or will do during the policy, unless the firm holds additional capital under IPRU(INV) 13.1.23R
  • carry an excess of no more than £5,000 on any claim, unless the firm holds additional capital under IPRU(INV) 13.1.27R
  • not limit cover where the firm, a fund it recommended or another person defaults, and state that it complies with IPRU(INV) 13.1.20AR

Insurers price advice firms on what they have advised on. Expect detailed questions on pension transfers, unregulated investments and high-risk products. Our FCA PII requirements guide sets out every limit, excess and capital top-up in one place.

People: senior managers, certification and competence

Every authorised advice firm is a Senior Managers and Certification Regime (SM&CR) firm. Most small advice firms are core firms. Typical senior manager functions are SMF1 (chief executive) or SMF3 (executive director), SMF16 (compliance oversight) and SMF17 (money laundering reporting officer), with SMF9 (chair) or SMF27 (partner) where relevant. Each senior manager needs FCA approval and a statement of responsibilities. Since April 2026, firms have 12 weeks to submit an approval application while an individual covers a role temporarily.

Advisers themselves are certified, not approved. The firm assesses each adviser as fit and proper every year. Retail investment advisers must also hold an appropriate qualification and a current Statement of Professional Standing from an accredited body. Pension transfer advice needs a pension transfer specialist with the additional qualification. Our SM&CR service covers responsibilities maps, statements of responsibilities and certification.

What goes in the application

The FCA judges the application against the threshold conditions: a UK address, effective supervision, appropriate resources, suitability, and a business model that is suitable for the firm and its clients. A complete, consistent file is the single biggest factor in how fast it is decided.

DocumentWhat the FCA looks for
Regulatory business planTarget clients, services, charging structure, ongoing service, distribution, investment proposition and growth plans
Financial projectionsThree years of forecasts with capital headroom against IPRU(INV) 13, and a stressed case
Wind-down planHow the firm would close in an orderly way, and what it would cost
Compliance monitoring programmeWho checks advice files, how often, and how findings reach the board
Consumer Duty evidenceTarget market, fair value of charges, how ongoing service is delivered and evidenced, vulnerable clients
PIIA policy or firm quote that meets IPRU(INV) 13.1
PeopleSMF applications, controllers, close links, organisation chart, training and competence scheme
Financial crimeAML risk assessment and procedures, sanctions screening

The FCA reads the business plan against the projections and the people. If the plan promises an ongoing service at a set price, it expects the projections to cost that service and the staffing to deliver it.

Timescales and fees

StepWhat happensTypical timing
PreparationBusiness plan, projections, policies, PII quote, SMF candidatesDepends on how ready the firm is
SubmissionApplication and Category 4 fee (£2,820, non-refundable) paid through ConnectDay 0
AssessmentCase officer review, questions, possible interview of senior managersStatutory limit 6 months if complete, 12 months if incomplete
DecisionPermission granted, possibly with requirements, or refusedOnce granted, update the FCA Register and start trading

The Government confirmed on 12 May 2026 that it will cut the statutory limits to 4 months for complete applications and 10 months for incomplete ones. That change is in the Financial Services and Markets Bill and is not yet in force. The FCA already measures its own performance against the shorter limits from January 2026.

The application fee is a one-off. Once authorised, the firm also pays annual FCA fees and levies for the Financial Ombudsman Service, the Financial Services Compensation Scheme and the Money and Pensions Service. Build all of them into the projections.

After authorisation: what changes on day one

Authorisation is the start of ongoing obligations, not the end of the project. A new advice firm should have these working from the first client:

  • Retail Mediation Activities Return (RMAR) reporting, including capital and PII self-certification
  • capital monitoring against IPRU(INV) 13, with an early warning if headroom falls
  • file checking and compliance monitoring, with findings reported to the board
  • the Consumer Duty annual board report and outcome monitoring
  • ongoing service delivery records, so every ongoing charge can be matched to a service delivered

The advice rules themselves are changing. The FCA's CP26/10 proposes replacing the annual suitability review with periodic reviews based on client needs, and the FCA aims to publish final rules in a policy statement in Q4 2026. Our guide to the ongoing advice rules and CP26/10 explains what to build now.

How Regulatory Counsel helps advice firms become directly authorised

We prepare the full application: permissions scoping, regulatory business plan, financial projections, wind-down plan, compliance framework, SM&CR documents and Consumer Duty evidence. We also manage the FCA's questions through to a decision. See our licensing and authorisation service and our investment and wealth firms sector page.

References

This article is general information as at 15 November 2026 and is not legal advice.

Frequently asked questions

How much capital does a directly authorised financial adviser need?

Under IPRU(INV) 13.13.2R, a personal investment firm needs the highest of £20,000, a percentage of annual income (5% for most advice firms that do not hold client money, 10% for others), and £500,000 if it provides targeted support. For a typical new advice firm that is £20,000 until annual income passes £400,000.

What PII limits does a financial adviser need?

A firm that is not an IDD insurance intermediary needs at least £500,000 per claim and £500,000 in aggregate if relevant income is up to £3 million, or £650,000 and £1,000,000 above that. An IDD insurance intermediary needs at least EUR 1,300,380 per claim and EUR 1,924,560 in aggregate. The excess cannot exceed £5,000 without additional capital.

How much is the FCA application fee for a financial adviser?

Most financial adviser applications fall into the FCA's Category 4, which is £2,820. The fee is paid through Connect when the application is submitted and is non-refundable.

How long does FCA authorisation take for an advice firm?

The FCA must decide a complete application within 6 months and any application within 12 months of receipt. The Government plans to cut these to 4 and 10 months through the Financial Services and Markets Bill.

Can I move from appointed representative to directly authorised?

Yes. You apply for your own Part 4A permission while still working as an AR, then end the AR arrangement when the FCA grants permission. Plan PII carefully: your former principal's PII should cover your AR history, and your new policy must cover your business from the date you are authorised.

Do I need SM&CR approval to run my own advice firm?

Yes. Senior managers in an authorised advice firm, such as the chief executive or director, the compliance oversight function and the money laundering reporting officer, need FCA approval before they take up their roles. Advisers are certified by the firm each year rather than approved by the FCA.

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