REGULATORY SERVICES

Variation of Permission

Adding, modifying or removing regulated activities on an existing FCA payment institution or EMI licence.

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HOW WE CAN HELP

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.

01

Permission Mapping

We identify exactly which permissions need to be added, varied, or removed.

02

Gap Analysis

We assess your current arrangements against requirements for the proposed new permissions.

03

Application Preparation

We prepare the VOP application with all supporting documentation.

04

Submission & Management

We submit and manage the regulatory review process through to approval.

DELIVERABLES

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 WE WORK WITH

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 REGULATORY COUNSEL

Why Work With Us

Financial Services Only

We operate exclusively within regulated financial services. Every member of our team has direct regulatory experience in this sector.

Senior-Led Delivery

Every engagement is led by a senior consultant with hands-on regulatory experience — not delegated to junior staff.

Practical, Not Theoretical

We build frameworks that work in practice, not just on paper. Our advice is grounded in what regulators actually expect.

Global Reach

We advise across 65+ jurisdictions, combining local regulatory knowledge with a consistent, high-quality approach.

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Frequently 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.