The application is in — or about to be — and customers are asking about finance today. Can you start before the FCA says yes? The short answer is no, and it catches people out, because the workarounds people reach for range from perfectly legal to criminal. Here's exactly where the line sits, what you can legitimately do while you wait, and how to make the wait as short as possible.
The short answer
No. FCA authorisation is binary: until the FCA has actually granted your permission, arranging finance for customers or introducing them to a lender is a regulated activity you cannot carry on. Submitting an application changes nothing about that. There is no provisional status, no grace period, and no comfort in "it's with the FCA" — an applicant firm has exactly the same permissions as a firm that never applied at all: none.
That matters because the consequences of jumping the gun are serious. Carrying on a regulated activity without authorisation breaches the general prohibition in the Financial Services and Markets Act 2000 — a criminal offence — and can make the resulting credit agreements unenforceable. The full picture of what's at stake is in our guide to offering finance without FCA authorisation.
"But we've applied — doesn't that count for anything?"
Legally, a pending application confers no rights. You won't appear on the Financial Services Register while your application is being assessed, and there's a practical wall behind the legal one: mainstream finance providers won't onboard a broker without a Firm Reference Number. Even if you were tempted to start early, the lender's own compliance team would stop you at the door.
Nor does submission start any clock after which you may trade. The only clock that runs is the FCA's decision window — covered in our guide to how long authorisation takes.
Four things you can legitimately do while you wait
1. Take payment that isn't credit
Cash, card and bank transfer are always fine, as is a deposit followed by the balance on delivery or completion. The line to watch: letting customers pay after you've supplied the goods or service, in instalments, is credit — and arranging it is regulated unless a specific exemption applies.
2. Use the narrow 0% exemption — properly
Genuinely interest-free credit repayable in 12 or fewer instalments within 12 months, with no charges of any kind, sits outside regulation. It's a real bridge for some businesses, but the conditions are strict — a single admin or late-payment fee destroys the exemption — and it's useless for longer plans. The precise rule is in our guide to 0% finance without authorisation.
3. Become an appointed representative in the meantime
The fastest lawful way to offer regulated finance now is under someone else's permission: become an appointed representative (AR) of an authorised principal — often a patient- or retail-finance provider. Once the principal has appointed you and notified the FCA, you can trade under their authorisation. Plenty of firms run as an AR while their own direct application progresses, then make the switch — we've written a separate guide to moving from AR to direct authorisation. Do check your principal agreement allows a parallel application.
4. Build the machinery so day one is a switch, not a start
Use the waiting time well: choose your lender panel and get onboarding paperwork ready to fire the moment your FRN exists; draft your finance advertising to the financial promotions standard; train the team on how finance conversations will run; settle your commission-disclosure wording. Firms that do this go live the day approval lands.
The trap: "soft" introductions
There is no informal tier of credit broking. Leaving a lender's leaflets on the counter, telling customers "most people use X", or passing a customer's details to a finance company are all ways of effecting introductions — the regulated activity itself. Volume and formality are irrelevant.
If a customer ends up in front of that lender because of you, you introduced them. There is no de minimis level of credit broking — one introduction is enough.
When the wait ends
Approval brings your Firm Reference Number and your entry on the register, and from that moment the machinery you prepared switches on: lenders complete onboarding against your FRN, and your promotions go out carrying the details the rules require. What that first stretch looks like is covered in what happens after the FCA approves your application.
Making the wait shorter
You can't hurry the FCA, but you control the one thing that most affects the outcome: the quality of what you submit. On timing, the decision is the FCA's and it does not commit to a date. Incomplete applications are the main cause of delay: the FCA's assessment does not begin in earnest until it has everything it has asked for. Our pack is ready in three business days* once we have your details from your deposit, and we file it the same business day you approve it — then handle the FCA's questions until the decision.
Frequently asked questions
- Is there a provisional or temporary licence while I wait?
No. For new applicants there is no interim or provisional status — the old “interim permission” regime was a one-off transition from the OFT era and closed years ago. Until your permission is granted you may only offer regulated finance as an appointed representative of an authorised principal.
- Can I take deposits or staged payments before I'm authorised?
Yes — payment in advance, on delivery, or a deposit plus balance on completion isn't credit. The line is crossed when customers pay after supply in instalments: that's credit, and arranging it is regulated unless the strict 0% exemption (12 or fewer instalments within 12 months, no charges at all) applies.
- Can we advertise that finance is “coming soon”?
A neutral statement that you've applied for FCA authorisation is fine. Promoting specific finance products or lenders before you're authorised is not — a financial promotion for credit must be made or approved by an authorised firm. Keep it generic until your permission is in force, then follow the promotions rules.
- If I withdraw and reapply, does the clock reset?
Yes — a new application starts the assessment again, and the FCA's application fee is non-refundable, so you pay it again too. It's one more reason the economics favour submitting a complete, well-prepared application first time. See our breakdown of the FCA's fees.
This article is general information to help you understand the process, and is not legal or regulatory advice. CreditLicence is a regulatory consultancy; nothing it provides is regulated advice, and it is not affiliated with, endorsed by, or acting on behalf of the FCA. FCA fees and rules can change; always check the FCA's website for the current position.