The short answer

You don't need accounts, revenue or a trading track record to get FCA authorised. The FCA authorises brand-new companies every week — including firms set up specifically to hold the permission before trading begins. What changes without history is what your application has to prove: instead of showing what the business has done, you have to show, credibly and in detail, what it's going to do. That's a different job, not a harder one — provided the application is built for it.

What the FCA is actually assessing

Every applicant, new or established, has to satisfy the FCA's threshold conditions. In plain English the case officer is asking three things: is the business model clear and lawful, does the firm have the resources — money, people, systems — to run it properly, and are the people behind it fit to hold the permission? A trading history is one way of evidencing those answers. It is not the only way, and for limited permission firms it has never been a requirement.

What replaces the track record

Four things do the work that accounts would otherwise do:

  • A credible regulatory business plan. Not a marketing document — a regulator's document: what you'll sell, who to, how finance fits in, which regulated activities you're applying for and why, and how you'll comply. Generic, templated plans are the classic rejection trigger; a pre-trading plan has to be specific about a business that doesn't exist yet, which is precisely where the skill lies.
  • Year-one financial projections. With no accounts to file, forecasts carry the load: expected volumes, income from finance, costs, and the working capital that carries you to breakeven. The FCA isn't marking you on ambition — it's checking the numbers hang together and the firm won't be running on fumes by month four.
  • A clear funding statement. Where the startup money comes from — share capital, director loans, savings — and that it's actually there. Unexplained or purely hypothetical funding is a soft spot case officers push on.
  • The people. Your SMF29 holder is assessed as fit and proper regardless of how new the company is — and relevant experience from earlier roles is exactly how a new firm evidences competence. Past financial or legal history isn't automatically a blocker, but candour about it is non-negotiable.

"Ready, willing and organised" — what it means in practice

The FCA expects applicants to be ready to carry on the activity shortly after authorisation, not someday. For a new firm that means the basics exist before you apply: the company is incorporated, a business bank account is open or in progress, you know which lenders or finance providers you intend to work with, you have premises — a home address is fine — and your policies aren't aspirational documents but ones you could follow on day one. Applying before any of that exists is the most common way new firms turn a straightforward application into a long correspondence.

The pattern behind most delays for new firms isn't the lack of history — it's inconsistency. Projections that don't match the plan, a funding figure that differs between forms, an activity described in one section and missing from another. Complete and consistent beats established every time.

The traps that catch new applicants

Three recur. First, vagueness: "we'll offer finance to customers" is a sentence, not a business model — the FCA wants the mechanics. Second, borrowed paperwork: a business plan or policy set copied from another firm reads as exactly that, and invites the follow-up questions it was meant to avoid. Third, applying for the wrong scope: new firms often under-apply (missing debt adjusting they'll need for part-exchanges, say) or over-apply (requesting full permission when limited permission covers the plan). Scope errors are expensive because the FCA's fee is non-refundable if it goes wrong.

Sole trader or limited company first?

Both can be authorised, and plenty of applicants incorporate specifically for the application. The structure affects who the FCA assesses and what happens if you incorporate later — we compare the two in sole trader vs limited company. If you're planning to incorporate anyway, doing it before applying is usually cleaner than switching afterwards.

What it costs

There are two separate costs to budget for:

  • The FCA's application fee — currently around £560 for a limited permission firm, paid to the FCA when the application is submitted. The FCA sets and occasionally changes its fees, so check the current figure on its website.
  • Preparing the application — you can do it yourself, pay a compliance consultancy (often £2,000 or more), or use a fixed-price service. This is where the cost varies most.

There's also a small annual fee to the FCA once you're authorised. On timing, six months is the FCA's statutory limit for deciding a complete application — and longer if it's incomplete. In practice, complete limited permission applications are often decided more quickly, though that's typical rather than guaranteed. The single biggest factor in avoiding delay is submitting a complete, well-prepared application the first time.

How we handle pre-trading applications

Applications for firms with no trading history are routine work for us: the business plan is written around your actual intended model, the year-one projections are built from your inputs so they reconcile to the plan and the funding statement, and the permission scope is set to what the model genuinely needs — nothing missing, nothing padded. Then we file it and deal with the FCA's questions. The timeline guide covers what to expect after submission.