Stage 1 of 5
Scope the permission profile
Decide exactly which regulated activities you carry on, so the application asks for the right permissions, falls in the right fee category and asks for nothing it does not need.
What happens at this stage?
Fact-find on the business model
We work through what you sell, to whom, how money flows and who does what, so the scope reflects the business you will actually run.
Map each activity to the perimeter
Each activity is tested against Schedule 2 FSMA and the FCA's Perimeter Guidance manual (PERG): dealing, arranging, managing, advising, accepting deposits and more.
Choose the route
Authorisation, an exclusion or exemption, or appointed representative status under a principal (for payments and e-money, acting as an agent or distributor of an authorised institution). Each has different costs, controls and timing.
Agree the permission profile
The permissions and any limitations to apply for, with the reasoning written down so the plan and the application tell the same story.
What MEMA prepares
Permission profile and perimeter analysis
An activity-by-activity view of what is regulated, what is not and why.
Route recommendation
Whether to apply directly, rely on an exclusion or exemption, or become an appointed representative.
Application plan
Workstreams, owners and the evidence needed, so the build starts with a clear brief.
Common delays / risks
Wrong permission set
Over-applying means unnecessary fees and scrutiny; under-applying leaves you unable to carry on part of the plan.
Activities outside the perimeter assumed
Carrying on a regulated activity without authorisation is a criminal offence under section 23 FSMA.
Permissions that match the business
The FCA decides what a firm may do from the activities it applies for, and tests the application against the business plan. The permissions requested therefore have to line up, activity for activity, with the business you describe.
What the FCA looks for in the scope
- Each regulated activity named and described in plain terms
- Permissions consistent with the business plan, customers and products
- Any limitations you want, with the reasons for them
- Clarity on the firm's structure, ownership and where it is run from
Investment, credit and insurance routes
- Part 4A permission under FSMA, covering the regulated activities you list
- A choice between full and limited permission where the activity allows it
- Exclusions and exemptions assessed before you commit to applying
Payments and e-money routes
- Which of authorised payment institution, small payment institution, e-money institution, or registration as an account information service provider (RAISP), fits the model
- Which payment services you will provide, and whether you use agents or distributors
- Choosing the wrong permission is a common cause of delay and re-work, so we settle it before you apply
What goes into the scoping file
- Activity-by-activity perimeter analysis with reasoning
- A short business model summary: customers, products, revenue and distribution
- The proposed permissions and limitations, with the rationale
- Group, ownership and intended UK location of the firm
Why this is written down
The scoping file becomes the spine of the application. When the regulatory business plan, the forms and the policies are drafted later, each is checked back against it.
Where scoping goes wrong
Over-applying
Asking for permissions the business does not need raises the application fee, widens what the FCA examines and slows the review.
Under-applying
Missing an activity means carrying it on without permission or returning to the FCA for a variation shortly after authorisation.
The wrong route
A firm that could operate as an appointed representative may not need its own permission, and the reverse is also true.
Before you trade
Section 19 FSMA prohibits carrying on regulated activities in the UK without authorisation or an exemption. If you need to operate urgently, appointed representative status can be an interim arrangement while your own application is prepared.