Business scope and permission boundaries
Undertaking regulated funeral plan provider obligations requires the applicable direct authorisation based on the actual contracts and funding structure; ordinary funeral service registration is not a substitute.[1]
Application value and choice of route
Select the minimum sufficient combination of permissions that lawfully supports the actual business, client scope and financial responsibilities, rather than treating the broadest permissions or fastest approval as the sole objective.
Before selling or assuming obligations under a scheme, clarify the regulated activities, safeguarding arrangements and responsible persons, avoiding presenting ordinary company registration as financial authorisation.[1]
Separate plan assets, standalone company finances, capital and cash flows to provide a verifiable basis for long-term performance of obligations and the firm’s solvency.[1] [2]
Determine resource requirements according to whether the business involves provision, pure distribution or additional regulated activities, rather than merely seeking the lowest share capital figure.[2]
Application conditions and entry requirements
Submit a complete business plan and materials on staffing and financial resources, and be able to provide standalone company financial statements excluding trusts; continually demonstrate compliance with the threshold conditions.[1]
Shareholders, directors and key personnel
Shareholders, controllers, directors and those actually responsible must be reviewed under applicable authorisation, governance and fitness requirements. The institution must be able to explain actual responsibilities and its supervisory, financial and programme management capabilities, and identify functions requiring approval under the applicable senior management regime. This guide does not invent a uniform number of directors, fixed certificates or a requirement for all personnel to reside in the UK.[1]
Capital and financial resources
Under FPCOB15.5, the requirement is generally the highest of £20,000, 2.5% of annual income and the amount calculated using the prescribed risk formula for undrawn commitments, while also meeting general solvency, liquidity and other applicable requirements.[2]
Registered office and operational substance
The application should identify the actual entity, regulatory contact details, business execution and oversight arrangements, and ensure that FCA can supervise effectively. A website or registered office address alone does not demonstrate operational capability; overseas structures, outsourcing and principal firm arrangements must be consistent with the actual business plan.[1]
Application document checklist
Regulatory business plan, list of permissions sought, complete application forms and supporting materials.[1]
Ownership and governance arrangements, information on proposed responsible persons, responsibilities, fitness and propriety, and applicable personnel approval materials.[1]
The provider's plan contracts, arrangements for holding or safeguarding funds, and standalone financial information; where statutory accounts and trust accounts are consolidated, the company's standalone financial position excluding the trust must be available.[1]
Revenue, unused plan data, capital, cash flow and adverse scenario calculations, recording key risks and mitigating measures.[2]
This is provided as a reference for organising the project; it cannot replace current official application forms or case-specific requests for additional materials. Please do not send identity documents or customer records through website forms.
Application process and key steps
First confirm the authorisation or intermediary AR route based on the obligations actually assumed and distribution activities, and read the FCA guidance, threshold conditions and applicable FPCOB.[1]
Prepare the business plan, staffing, financial resources and financial projections, and check that each permission matches the proposed activities.[1]
For direct authorisation, submit a complete application and supporting materials through Connect and pay the non-refundable application fee. Providers fall within fee category 5 and intermediaries within category 4; verify current amounts on the FCA fees page, and do not treat fees as capital.[1]
Address completeness checks, requests for additional documents and assessment requirements, and begin operations only after obtaining the corresponding approval and meeting the conditions for implementation; subsequent changes remain subject to applicable procedures.[1]
Approval deadlines and project timelines
For direct authorisation, completeness and statutory decision periods must be assessed under provision 55V of FSMA and the actual application category. These are generally six months for complete applications and twelve months from initial receipt for incomplete applications, subject to any applicable statutory exceptions. This is not a guaranteed overall timetable to approval and operation; preparation, principal due diligence, funding arrangements and supplementary submissions must be allowed for separately. Acceptance of an intermediary as an AR is also not equivalent to a direct authorisation decision.[1] [3]
Changes to shareholders, directors and permissions
Adding funeral plan activities to an existing authorisation requires checking VoP. Changes in shareholdings and controllers require separate review of change-in-control procedures, while personnel changes are handled according to the actual approved functions and regulatory notification requirements. Changes to an intermediary AR's principal, scope of responsibility or operating model require separate confirmation; registration as a company director does not replace regulatory approval.[1]
Ongoing compliance and annual maintenance
Continue verifying plan funds, performance, revenue and unused contract data, recalculating core capital and retaining risk assessments; do not treat trust plan assets as wholly available operating capital of the company.[2]
Acquisition due diligence and transaction considerations
Before acquisition, verify the actual legal entity, FRN, permissions to provide or distribute, AR relationships and restrictions. Purchasing an ordinary company certificate does not enable the assumption of plan obligations. Reassess unused and legacy plan data, trust or insurance backing, standalone financials, revenue, capital, cash flow and performance shortfalls, and check contractual change-of-control provisions, service providers and consumer responsibilities. Where triggered, shareholding control, VoP and key personnel approvals should each be addressed before completion; regulatory consent is not guaranteed.[1] [2]
View the complete process for acquiring a licensed companyBusiness segments and applicable regimes
The following are specific permissions, organisational models or statutory categories covered by this topic. They do not necessarily each constitute a separate financial licence.
Frequently asked questions
Is preparing only £20,000 sufficient for a provider?+
No. It must be compared with 2.5% of annual income and the amount calculated for unused-plan risk, taking the highest. General solvency, liquidity and other applicable rules may still require greater resources.[2]
Does ordinary funeral company registration amount to FCA authorisation?+
No. The provision and distribution of regulated plans must be checked separately against the actual activities. Company incorporation and authorisation for financial activities are different matters.[1]
Can client trust money be used as the company's capital?+
These cannot simply be combined. FCA requires the ability to provide standalone company financial statements excluding the trust. Capital inclusion and deductions separately follow FPCOB15; funds for meeting plan obligations differ from the institution's financial resources.[1] [2]
Can an intermediary AR relationship replace authorisation as a plan provider?+
This cannot be extended mechanically. Under AR, the principal assumes responsibility for the activities actually accepted, and the specific scope must be checked. Obligations to provide services and permissions are assessed against the actual business model.[1]
Official basis and verification sources
Primarily based on FCA, PRA / Bank of England, GOV.UK and current legislation. Older third-party guides supplied by users are used to organise business material and do not override the latest official requirements.
Tang Shangyong (Mr Tang / Drew) · Business Manager
Global financial licence application, transaction and ongoing compliance services