Variation of Permission (VoP) Applications

Adding, amending or removing FCA-regulated activities. We manage VoP applications from assessment through to approval.

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What We Do

A Variation of Permission (VoP) application is required when an FCA-authorised firm needs to add, amend or remove regulated activities from its permission profile. We manage the full application process from assessment through to FCA approval.

What Triggers a VoP?

A Variation of Permission is required when a firm wants to add new regulated activities (e.g. adding AIS/PIS to an existing PI licence), remove activities it no longer provides, change limitations or requirements attached to its permissions, or expand into new service categories. VoP applications are also common when SPIs transition to API status or when firms expand from payment services into e-money issuance.

Common Scenarios

  • Adding Account Information Services (AIS) or Payment Initiation Services (PIS)
  • Transitioning from SPI to Authorised Payment Institution (API)
  • Expanding from PI to EMI authorisation
  • Adding new payment service types to an existing licence
  • Removing activities that are no longer provided
  • Changing or removing limitations and requirements

Application & FCA Liaison

We prepare the VoP application form, supporting documentation and any updated regulatory submissions required. This may include revised business plans, updated programme of operations, additional governance arrangements, updated capital calculations and new or revised policies. We manage all FCA correspondence and queries through to approval.

Timelines

VoP application timelines vary depending on complexity. Simple variations (e.g. removing an activity) can be processed within weeks. More complex variations (e.g. adding new regulated activities or transitioning licence type) typically take 3–6 months. We provide a realistic timeline assessment at the outset and keep you informed throughout.

Frequently Asked Questions

A VoP is an application to the FCA to add, amend or remove regulated activities from a firm’s permission profile. It is required whenever a firm’s regulated activities change.

Simple variations can be processed in weeks. Complex variations (adding new activities, changing licence type) typically take 3–6 months.

Yes. Adding AIS (Account Information Services) or PIS (Payment Initiation Services) to an existing PI or EMI licence requires a VoP application.

The transition from SPI to API is technically a new authorisation application rather than a VoP, but we manage the process seamlessly and ensure continuity of operations.

This depends on the variation. Adding new activities typically requires an updated business plan, programme of operations, governance arrangements, capital calculations and relevant policies.

Yes. We manage applications to cancel or remove regulated activities, ensuring the FCA records accurately reflect your current operations.

Speak to Our Team

Get in touch to discuss how we can support your regulatory and compliance needs.

info@regulatorycounsel.co.uk | 2 Frederick Street, London WC1X 0ND