Free tool

FCA application readiness checker

Twenty-five questions on what the FCA asks a payment institution applicant for. See which parts of your pack are ready and which are not.

This is a self-assessment tool, not regulatory advice. It reflects published FCA requirements and cannot account for your firm’s circumstances. It does not predict whether an application will be approved, and no score here means anything about the outcome of an application. Check anything you rely on against the FCA’s own guidance and take your own professional advice. Sources current as at 2026-09-03.
First, which route applies?

What are your projected monthly payment transactions, averaged over 12 months?

PERG 15.4 Q26: the average of the preceding 12 months' payment transactions "does not exceed 3 million euros (or an equivalent amount) per month". Small PIs also cannot provide account information services or payment initiation services — a firm wanting either must become an authorised PI. FCA Handbook, PERG 15.4

Business plan and financial projections

15% of the overall picture

Do you have a programme of operations describing each payment service you intend to provide?

Do you have a business plan with financial projections, including a forecast budget? (API only)

Do you have a wind-down plan? (API only)

Can you evidence the initial capital required for your service type, held immediately before authorisation? (API only)

Safeguarding

20% of the overall picture

Have you chosen your safeguarding method? (API only)

If using segregation, have you identified the account arrangement and can you show relevant funds are kept separate from your own? (API only)

Do you have a documented reconciliation process for safeguarded funds? (API only)

Have you decided whether to safeguard voluntarily, and recorded that decision? (SPI only)

Anti-money-laundering and counter-terrorist financing

20% of the overall picture

Are you registered with HMRC as a money service business, or is an application in progress?

Do you have a written firm-wide AML/CTF risk assessment?

Do you have documented control mechanisms to meet your obligations under the Money Laundering Regulations?

Have you appointed an MLRO, and can you evidence their knowledge and experience?

Do you have documented customer due diligence procedures, including enhanced due diligence triggers and sanctions screening?

Governance, fitness and propriety

15% of the overall picture

Can you identify everyone with a qualifying holding, and evidence that each is a fit and proper person?

Are your directors and managers of good repute, with appropriate knowledge and experience to provide payment services?

Have you confirmed that nobody managing or operating the business has a relevant criminal conviction?

Is your head office or registered office in the UK, and will you carry on payment services business in the UK?

Do you have documented governance arrangements, internal controls and risk management procedures? (API only)

Operational and IT resilience

15% of the overall picture

Do you have documented procedures for incident reporting, data management and business continuity?

Do you have a security policy, and a policy for security-related customer complaints?

Do you know your major-incident reporting obligations and how quickly you must notify?

Have you documented any outsourcing arrangements and plans to use agents or distributors?

Complaints and consumer outcomes

8% of the overall picture

Do you have a complaints handling procedure, and do you know your Financial Ombudsman Service obligations?

If you will provide account information or payment initiation services, do you hold professional indemnity insurance or a comparable guarantee? (API only)

Regulatory reporting readiness

7% of the overall picture

Do you know which regulatory returns you will file, and can your systems produce them?

Your answers are not stored. They are encoded into the result link, so you can share it with your compliance consultant or come back to it later.

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