FCA Authorisation Support: The Senior Team Your Application Depends On
When the FCA assesses an application for authorisation, it doesn’t just read the business plan. It looks hard at the people who will run the firm: whether they are fit and proper, whether they have the right experience, and whether the senior team as a whole can manage the risks of the business. Many applications that stall or fail do so because of the people, not the paperwork. SMF Capital provides FCA authorisation support from that angle. We identify, assess and secure the Senior Managers your application needs, in the right order and before you submit, so the regulator sees a credible team from the first day.
What FCA Authorisation Support Means Here
Most firms seeking authorisation work with several advisers. A regulatory consultancy or law firm usually prepares the application itself: the regulatory business plan, policies, procedures and financial projections. SMF Capital does something different and complementary. We find the people the application names.
That matters because the FCA authorises a firm with named, individually assessed senior managers. Under the threshold conditions, a firm must have suitable management and be capable of being effectively supervised. In practice, that means the people holding Senior Manager Functions must be approved, and the regulator must be satisfied that the senior team has the experience, time and standing to run the firm properly. A strong business plan with a weak or incomplete team is one of the commonest reasons for delay. Our guide to threshold conditions and Part 4A permission explains the framework in full.
Who We Support
We work with firms at every stage of the authorisation process, across the regulated sectors:
| Situation | Typical people needed |
|---|---|
| New firm applying for Part 4A authorisation | Chief executive, compliance officer (SMF16), MLRO (SMF17), finance lead, and often a chair or independent non-executive |
| Payment institution or e-money institution | Compliance and MLRO leadership with payments experience, a safeguarding-literate finance lead, and directors the FCA will assess |
| Appointed representative going directly authorised | A compliance officer who can stand alone without a principal’s support, plus an MLRO and finance oversight |
| Authorised firm applying for a variation of permission | Additional Senior Managers or new expertise for the activities being added |
| Firm becoming Enhanced, or moving into a new regulatory tier | Additional SMF roles such as chief risk officer or head of internal audit, and board committee chairs |
| Overseas firm opening a UK branch or subsidiary | UK-based Senior Managers, including the head of the branch, with UK regulatory experience |
For payments and e-money applications specifically, see the people needed for payments and e-money authorisation. For firms leaving an appointed representative arrangement, see going directly authorised: the Senior Managers you’ll need.
Why Sequencing Is the Whole Problem
Authorisation is assessed on the team you name, not the team you intend to hire later. That creates a timing problem. Experienced Senior Managers are reluctant to commit to a firm that isn’t yet authorised, and firms are reluctant to pay senior salaries before they can trade. Yet the application needs named, credible people, and the regulator will scrutinise each of them.
Solving that problem is mostly about order and structure:
- Identify which functions you need. The Senior Manager Functions that apply depend on your permissions and your expected regulatory tier. Our guide to which SMFs apply at which firm tier sets this out.
- Decide which roles must be in place at submission. Some roles, particularly the compliance officer and MLRO, are central to almost every application. Others can follow once the firm is trading.
- Choose the right model for each role. Full-time, fractional or interim, depending on the firm’s size and risks, and how each will scale after authorisation.
- Secure candidates early. Agree terms that work through the application period, often with a conditional start or a fractional arrangement that becomes full-time on authorisation.
- Complete the checks. Fit and proper assessments, background checks and regulatory references must be done before the approval applications go in.
- Prepare the documents. Statements of Responsibilities and, where needed, a Management Responsibilities Map that reflect a deliberate structure, not a template.
Our article on the authorisation journey: building an SMF team from scratch walks through this sequence in more detail.
What We Help You Build
A credible compliance oversight function
The compliance officer holding SMF16 is often the appointment the FCA examines most closely in a new firm. We identify candidates whose experience matches your business model and permissions, and who can explain to the regulator how they will run compliance from the first day. See compliance officer recruitment (SMF16).
An MLRO proportionate to your financial crime risk
For payments, e-money and cryptoasset firms in particular, the MLRO can make or break an application. We find SMF17 candidates and nominated officers with experience of comparable risk profiles, and who can show the regulator a credible financial crime framework. See MLRO recruitment (SMF17). Where one person will hold both roles at a smaller firm, see combined compliance officer and MLRO recruitment.
The executive and finance leadership
The chief executive and finance lead must both satisfy the regulator. Founders often hold the chief executive role, and the FCA will look at their experience of regulated business. Where it is thin, a strong supporting team or a non-executive chair can make the difference. See regulated CEO recruitment (SMF1) and CFO recruitment (SMF2).
A board proportionate to your scale
Many new firms benefit from an independent chair or non-executive director before submission. It adds challenge and experience to the governance the FCA reviews. See chair and committee chair recruitment.
Governance documents that reflect a real structure
Statements of Responsibilities that are generic, overlapping or copied from another firm undermine an application. We help make sure each Senior Manager’s responsibilities are clear and that the structure as a whole makes sense. Our Statement of Responsibilities template is a useful starting point, and our governance and SMF structure review tests the whole design.
Fractional and Interim Cover Through the Application
New firms rarely need full-time compliance and financial crime leaders on day one, but they need the experience and the regulator’s confidence. A fractional compliance officer or MLRO, working a set number of days a month, often gives the strongest combination: an approved, experienced Senior Manager named in the application, at a cost the firm can carry until it is trading. As volumes grow, the role can move to full-time or be handed to a permanent hire.
Interim cover helps where timing is tight, for example when a firm needs to strengthen its team quickly in response to questions from the regulator during the assessment. See fractional and interim SMF cover.
Timelines to Plan Around
| Stage | Typical timing |
|---|---|
| Recruiting a fractional compliance officer or MLRO | Often two to four weeks to a committed candidate |
| Recruiting a permanent Senior Manager | Usually six to twelve weeks to an accepted offer, plus notice period |
| Checks and regulatory references | Two to six weeks, depending on how many previous employers are involved |
| FCA decision on a Part 4A application | Up to six months from a complete application, and up to twelve months if incomplete |
| FCA decision on a payment or e-money institution application | Up to three months from a complete application, and up to twelve months if incomplete |
Statutory deadlines run from when the FCA considers an application complete, so gaps in the senior team or missing information extend the process. Starting the people side early is the most reliable way to keep the overall timetable on track. The FCA’s authorisation pages set out the regulator’s own process and guidance.
Example: A founder-led fintech planning an e-money application had a strong product team and a draft business plan, but no one with regulated compliance or financial crime experience. Recruiting a fractional compliance officer and MLRO, both with prior e-money authorisation experience, before submission meant the application named credible, approved-standard individuals from the outset. The firm also appointed an independent non-executive with payments experience to chair its board, giving the regulator a clear governance story.
Our Approach
We start with your target submission date and your business model, and work backwards. That tells us which Senior Manager Functions you need, which must be in place at submission, what model suits each role, and how long each search will take. From there, every search follows the same discipline: candidates are assessed against the regulator’s fit and proper test before they reach your shortlist, references and checks are started early, and candidates are prepared for any approval interview.
Every search is overseen by Adrian Lawrence FCA, and we coordinate with your regulatory consultant or lawyers so the people and the paperwork arrive together.
Building Your Senior Team for Authorisation
The approved people your application depends on. Every SMF search is overseen by Adrian Lawrence FCA
Control Functions
Compliance and financial crime leadership.
→ Compliance officer (SMF16) → MLRO (SMF17)SMF16 and SMF17 guide →
Payments
Payment and e-money institutions.
→ Payments authorisation people → Payments and fintechSafeguarding guide →
Flexible Cover
Fractional and interim Senior Managers.
→ Fractional and interim cover → Fractional MLROThe 12-week rule →
Planning
Getting the structure right first.
→ SMF structure review → Overseas firmsWhich SMFs apply →
Every SMF search is overseen by Adrian Lawrence FCA
Frequently Asked Questions
Do you prepare the FCA application?
No. We provide the people. Your application is usually prepared by a regulatory consultancy or law firm, and we work alongside them so the Senior Managers named in the application are in place and properly assessed.
Do our Senior Managers need to be in place before we apply?
The FCA expects the application to name the individuals who will hold the key Senior Manager Functions, and it assesses them as part of the application. They don’t always need to have started work, but they need to be committed and ready to be approved.
Can a new firm use a fractional compliance officer or MLRO?
Yes, provided the time commitment is proportionate to the firm’s size and risks and the individual has relevant experience. Many newly authorised firms start this way and move to full-time appointments as they grow.
Can a founder be the chief executive of a newly authorised firm?
Often, yes. The FCA will assess the founder’s experience and fitness for the role. Where regulated experience is limited, a strong supporting team and an experienced chair can strengthen the application.
How long does FCA authorisation take?
The FCA has up to six months to decide a complete Part 4A application and up to twelve months for an incomplete one. Payment and e-money applications have shorter statutory periods. Recruiting the senior team takes time too, so it should start well before submission.
Do you help with a variation of permission or change in control?
Yes. Adding permissions or changing ownership often means adding or replacing Senior Managers, and we recruit for both situations.
About Our Founder
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices. He oversees every SMF Capital search. View Adrian’s ICAEW profile.
Planning Your FCA Authorisation?
Tell us your target submission date and your business model. We’ll work backwards to the senior team you need and when each role must be in place, and come back to you the same working day.