Variation Of Permissions

A Variation of Permission (or ‘VOP’) is an application to the Financial Conduct Authority (FCA) that is used to request additional permissions, the removal of certain permissions and the removal or introduction of limitations on the permissions you already hold.

Such an application may be necessary if you want to start a new line of business, start conducting a new regulated activity or add a new product or client type to your business line.

When you obtain authorisation from the FCA you are permitted to conduct certain regulatory activities under the specific permissions granted to you by the FCA.

Different permissions are necessary for different activities, for example, you cannot make introductions for customers looking to take out a mortgage if you only have permissions relating to insurance.

The process is similar to applying for authorisation however a Variation of Permissions requires updated regulatory documents such as a new Regulatory Business Plan which would outline why the firm can, and wishes to, conduct this new activity.

Why do some firms hold Limited Permissions and others don’t?

You should also be aware that different compliance documentation may be required to help ensure that you are equipped to satisfy any new requirements resulting from the change to your permissions.

Additionally, other requirements may be captured that affect the amount of information that must be provided. For example, a Limited Scope firm under the Senior Managers and Certification Regime (SM&CR) may only have one Senior Management Function holder (SMF). By adding additional permissions, the firm may no longer be a Limited Scope firm and consequently may need to seek approval for a number of its directors or other senior managers to be appointed by the FCA as SMFs under the SM&CR.

Similarly, as a result of the variation, your fees, financial category, financial resource requirement and reporting requirement may change.

You cannot start the activities that you have requested under the Variation of Permissions application until your application is approved by the FCA.

Appointed Representatives and Principal Firms

Some firms that are authorised by the FCA can enter into an agreement enabling one or more non FCA-authorised firms to conduct regulated activity without first obtaining permission from the FCA. The FCA Authorised firm in this type of relationship is known as the Principal Firm whilst the other party is known as an Appointed Representative.

The nature of these relationships means that the Principal Firm is accountable to the FCA for ensuring the Appointed Representative complies with the FCA’s rules. For that reason, it normally comes at a cost to the Appointed Representative.

Many firms start as Appointed Representatives before seeking direct authorisation from the FCA, although this is not required.

For more information on Appointed Representatives and Principal Firms please click here.

How Can MEMA support you?

MEMA has been supporting firms through the FCA compliance process since 2019. In that time, we have helped hundreds of businesses to successfully gain and retain FCA authorisation.

We have a unique blend of experience from ex-regulators, big 4 consultants and fin/regtech specialisation. Our team is highly experienced and expertly skilled. We specialise in providing our clients with solutions to often complex regulatory requirements and compliance needs.

Our unique industry insight and comfort with compliance enables our team to support you to the fullest extent possible, helping to develop your business model and compliance.

When providing our variation of permission support, we help you throughout this process by completing the online application, drafting your revised business plan and providing a suite of compliance documents to help you remain compliant after successfully varying your permissions.  We’re also on hand throughout the process and afterwards to advice and support you and your firm.

Ongoing FCA Compliance

As an FCA authorised person or firm, you might need help to ensure you comply with the FCA’s rules.

We provide our clients with support they need to maintain compliance and avoid breaching the rules. Our bespoke service is individually tailored to each of our client’s requirements and objectives to help them meet in the best way possible.

Whether you need documentation to help you remain compliant, want ongoing advice or support, impartial monitoring of your activities or anything else, MEMA may be able to help.

Why Choose MEMA?

Get started!

MEMA has been supporting firms through the FCA compliance process since 2019. In that time, we have helped hundreds of businesses to successfully gain and retain FCA authorisation.

We have a unique blend of experience from ex-regulators, big 4 consultants and fin/regtech specialisation. Our team is highly experienced and expertly skilled. We specialise in providing our clients with solutions to often complex regulatory requirements and compliance needs.

Our unique industry insight and comfort with compliance enables our team to support you to the fullest extent possible, helping to develop your business model and compliance.

Contact us

March 24, 2025

Preparing for Future Challenges: Emerging UK Crypto Regulations and Strategic Planning

In the concluding part of our series, we shift focus to tomorrow’s regulatory environment—including pending legislation, potential expanded authorisation requirements, and international alignment trends.

More about us

March 31, 2023

Horizon Scanning for Compliance Officers in UK Banking & Payment Services Sector: Key Strategies

Horizon scanning is a key component of this role, as it helps compliance officers stay informed of emerging trends, changes in regulations, and technological advancements that could impact their organization. In this article, we'll provide key strategies and best practices for successful horizon scanning in the UK banking and payment services sector.

More about us

June 11, 2021

FCA Financial Promotions Quarterly Review

In our first of the series on regulatory smarts, we alert you to the quarterly financial promotion release issued by the FCA

More about us

Insights

May 2, 2021

Estate agency guidance for money laundering supervision- Part 1

If you are supervised by the HMRC for anti-money laundering purposes, you will need to meet requirements under the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017.
More about us
December 6, 2021

Funeral plans come under FCA regulation July 2022

The FCA has confirmed that from 29 July 2022, it will take on responsibility for regulating and supervising the pre-paid funeral plans market.
More about us
August 29, 2022

Who would be considered a Politically Exposed Person (PEP)?

“A Politically Exposed Person (PEP) is a natural person who is or has been entrusted with prominent public functions and includes his/her immediate family or persons known to be close associates of such persons, but shall NOT include middle ranking or more junior officials.”
More about us
April 11, 2021

Claims Management Companies and High Cost Lenders

In a recent post, the FCA has released its views urging Claims Management Companies and High Cost Lenders to work better together
More about us
January 16, 2023

What are the FCA financial promotions and what internal controls should you set up

A financial promotion is any advertisement, communication, or other material that promotes a financial product or service. Financial promotions can take many forms, including print and online advertisements, marketing emails, social media posts, and sales presentations.
More about us
January 28, 2022

What are regulatory controls and how do you conduct control monitoring

As a regulated firm or a firm wishing to become regulated, you will need to ensure you have a robust control plan and can conduct effective monitoring of controls. In this article, we will detail what a control plan is and the steps you can take to conduct effective control monitoring.
More about us
June 20, 2022

How to navigate the Skilled Person Review

As part of our How to series, we thought to release a brief guide on what to do when you are required to appoint a Skilled Persons by the regulator.
More about us
October 12, 2021

Understanding the Regulatory Landscape

At MEMA, in discussions with our customers (current and prospective) we identified a common theme, understanding the regulatory landscape is problematic and requires clearer descriptions aid understanding.
More about us
June 5, 2025

Twelve Years of FCA Enforcement: What £ 4.77 Billion in Fines Says About UK Financial Conduct

£ 4.77 billion in FCA fines since 2013. Explore annual trends, sector hot-spots and compliance priorities for 2025.
More about us
May 23, 2025

FCA Regulatory Brief – Priority Actions for Firms 9 May – 22 May 2025

The FCA’s announcements between 9 May – 22 May 2025 underscore three immediate themes for regulated firms
More about us
November 10, 2024

Putting Customers First: Insights from the FCA's £10.9 Million Fine on TSB

Learn from TSB's FCA fine for failing to treat customers fairly. Discover how to align your firm's practices with regulatory expectations with MEMA Consultants.
More about us
July 11, 2025

Crime, Clarity & Controls: This Week in FCA Action

This week, the FCA pulled no punches in its approach to market integrity and customer protection — issuing fines, securing convictions, and upgrading its regulatory infrastructure. Here's what matters and what firms should do next.
More about us
August 7, 2022

Preparing for the TPR Regime

The Temporary Permissions Regime ('TPR') was designed in response to Brexit to ensure that European firms operating in the UK via a passport could continue operating temporarily while they seek full authorisation in the UK.
More about us
June 12, 2022

How to write a FCA business plan

We intend on launching a range of How-To articles to help you understand and resolve your ongoing regulatory compliance matters. Our first instalment is a guide on how to write a regulatory business plan.
More about us
September 27, 2022

How to get FCA authorised (part 1)

We are launching a new How To series on 'How to get FCA authorised'. This will look to cover a range of key items your business should consider from the location of offices, expected fees to resourcing. We will start on the first few key areas covering
More about us

Your key contacts

ADEMOLA OMOSANYA

Ademola is an accomplished consultant with over a decade of experience across regulation, banking, and consumer credit. As MEMA Consultants co-founder, he leverages extensive regulatory expertise to guide clients through critical processes and full compliance. His experience across sectors enables tailored solutions to complex business challenges. Ademola partners with clients as a strategic advisor to help futureproof their business through an in-depth understanding of the regulatory landscape.

MISAH MARAGH

Misah is a director at MEMA Consultants with over a decade of experience in financial services. Holding a legal background and postgraduate qualification, she previously worked at the Financial Conduct Authority. Misah has led compliance transformation for global consumer services organisations across Europe, the Caribbean, and Latin America. Her expertise includes implementing compliance frameworks for financial regulations, FCPA, UK Bribery Act, data privacy, and Sarbanes-Oxley. Misah is skilled at advising clients on operational and strategic projects, leveraging her in-depth knowledge of regulatory environments to deliver solutions tailored to complex business needs.

Thank you! Your submission has been received!
Oops! Something went wrong while submitting the form.

Variation Of Permissions