Getting firms fit to run

Introduction

This weekend, tens of thousands of runners will line up in Greenwich Park for the start of the London Marathon.

Well done to them – a Netflix marathon is much more my speed.

Unlike what’s needed to prepare for a Netflix marathon – opening a bag of sweet and salty popcorn – Sunday’s runners will have been training for months. Many even years.

And nearly all will have had support along the way, whether from a coach, physio or friend at a parkrun.

What strikes me about that relationship is where the responsibility sits.

A coach designs the programme, corrects the technique and knows how to get a runner to the start line in the best possible shape.

But they’re not the ones lacing up their trainers. The runner is.

Getting authorised is more like a marathon than it might seem.

Filled with documents, deadlines and – let’s be honest – a fair amount of adrenaline, it can feel like that final sprint down the Mall for many firms as they reach the end.

And you are their support system, helping them get authorisation-ready.

That preparation genuinely matters.

Because gaining the right to be a regulated financial services firm isn’t easy.

Nor should it be.

Getting authorised is hard – but rightly so

Clean markets aren’t an abstract idea. They’re how we protect consumers, support confidence and encourage investment and growth.

So, standards have to be high. And we have to uphold them.

But we do want firms to succeed, and you are a key part of the process.

This may surprise those of you who’ve wondered whether we want third-party consultants involved in the authorisation process at all.

The answer is yes!

We value all those helping applicants get into the best position to reach the finishing line.

Identifying gaps, stress-testing their governance, sharpening their documentation and helping them understand the regulations is a critical part of this process.

And it’s when firms come to us well-prepared that the process works best, and firms get through the process quickly and smoothly.

The authorisation process is not about putting obstacles in the way.

It’s about filtering out those who:

• aren’t ready or don’t have viable business models
• have poor governance, systems and controls
• don’t want to put the customer at the heart of their business
• are bad actors – those who are seeking authorisation for nefarious reasons

This is how we continue to maintain a strong, trusted financial services sector.

And the evidence speaks for itself: FSCS compensation costs are falling, with the levy forecast to reduce in 2026/27.

A clear sign the firms being authorised are, broadly, the ones who deliver good customer outcomes.

Good third-party consultants

So, we're pro-third party – we love coaches!

As long as they’re also good.

In our eyes, ‘good’ professional support does three things.

One: Set clear boundaries.

The question at the starting line is simple: is your client fit to run?

You can help them train for that moment, but you can’t run the race for them.

When a firm sits down with us, it’s their competence we’re assessing. Not yours.

You are welcome in the room, but your client must be able to speak for themselves – and explain their business model and operations clearly, in their own words.

We can spot when a consultant has become the dominant voice in an application, whether in emails, meetings or interviews.

And where we do, we’ll address it directly with the firm’s senior management.

Let me give you an example.

A consultant recently attended an interview with their client, but began prompting the firm. At times, they even appeared to be coaching them by instant message.

We could no longer tell whose knowledge, skills and experience we were hearing about – the firm’s, or the consultant’s.

So we stopped the interview and rescheduled.

The firm did perform well at the follow-up call and was approved – but a month later than necessary, and under far more stress than they should’ve faced.

I should say: this kind of thing is rare, but when it does happen, the impact is significant.

So, it has to be the firm's voice – their words – that we hear. Not yours.

That matters beyond the meeting itself.

It speaks to a bigger responsibility: making sure firms are genuinely ready before they come to us.

You can’t claim to have run a marathon if someone else carried you.

Similarly, we won’t authorise a firm if we don’t think they:

• understand what it means to be regulated
• can demonstrate they understand their business model inside and out
• have confidence in how they will respond when something goes wrong…which it will

That brings me to the second thing good third-party consultants do.

They hold their clients to high standards.

A financial services market that consumers and investors can trust is one that works for everyone in it. Including your clients.

So we will not let our standards slip.

By keeping the bar high, we protect the reputation of the entire sector. And when firms get through, everyone knows they’ve earned their place.

We do support firms where we can to meet that bar, as demonstrated by the range of support services we provide.

But everyone in this room has a part to play.

Sometimes, it means having the hard conversations – like telling your clients they aren’t yet ready.

Or, sometimes, suggesting they withdraw to protect everyone’s time and safeguard the system’s integrity.

It’s often your guidance – not ours – that helps a firm see withdrawal is the wiser route.

And withdrawal shouldn’t be seen as a sign of failure.

It means showing good judgement, taking the space to regroup, and – most importantly – coming back stronger.

And that’s the final element of good professional support: being able to take a long view.

Of course, you already know the race being entered.

But courses change. Just last year, the London Marathon altered its Canary Wharf route.

So, the best coaches are always looking ahead.

Helping their clients adapt and succeed, regardless of what happens.

Your job isn’t just to get a firm through the door; it’s also to help set them up to thrive once they’re on the other side.

That means understanding not just where regulatory expectations are, but also where they’re going.

And making full use of every resource we offer to get there.

On our part, we are seeking to start earlier than we have in the past.

We launched the pre-application support service (PASS) for Targeted Support in August 2025 – a full eight months ahead of the gateway opening last month.

The first two firms were authorised on day two of the regime. Not bad, considering day one was a bank holiday!

If you haven’t already, I would encourage everyone in this room to build PASS into your standard process where we guarantee it.

Our Appointed Representatives regime is another key market entry point.

It can help businesses – particularly smaller ones – understand compliance needs under the watchful eye of a fully authorised good principal firm.

Putting them in a stronger position to go on and make a successful application for direct authorisation.

And while our crypto regime doesn’t open until September, we’re hosting a series of authorisations-focused webinars to help firms get ready.

We have on-demand sessions already available covering upcoming regulatory changes[2] and anti-money laundering regulations[3].

Next Wednesday we’re hosting a webinar on the Senior Managers and Certification Regime[4], followed by one on operational resilience[5] in May.

Plenty going on, so please do join us.

Beyond that, our website sets out the full application process, and we publish sector-specific market reports along with good and poor practice guidance.

For firms working on more innovative ideas, I’d encourage you to make full use of our innovation services of which there is a wide range.

Including our Regulatory Sandbox, where every firm now has a dedicated authorisation case officer.

Finally, our Minded to Approve initiative lets us give in-principle decisions earlier, so firms can focus on what comes next.

Make use of these services, and point your clients towards them too.

Because firms that engage with us early submit better applications – and that means faster decisions, less stress and better outcomes for everyone.

But let me be clear: our support services are not there to replace the hard work and preparation that should go into getting ready for authorisation.

Or to replace those who support them doing so – namely you in this room.

It’s about providing different forms of help to firms – and those working with them – to ensure they’re truly ready to apply and to meet the rigours of the process.

We all want the best firms to enter the market; to bring growth and wealth creation for the UK.

Looking ahead

As I mentioned earlier, the best coaches are already studying next year’s course and thinking about what their clients need to do to succeed.

Here’s what it looks like from where we’re standing: Getting authorised won’t get easier.

That wouldn’t be the right thing for the UK.

So now is the time to be preparing your clients.

Let me flag two things on the horizon that are worth putting in your diary now.

The first is Buy Now Pay Later (BNPL), which becomes regulated on 15 July.

If you're working with BNPL lenders, or firms considering entering the market, please point them our way.

The second is, as I have already mentioned, our new crypto regime.

The gateway opens in September, and from October 2027, crypto firms will need to be authorised to operate in the UK.

The bar will be high, and firms will need time to prepare.

But we want to work with them to clearly set out our expectations.

So, in addition to the webinars I mentioned earlier, pre-application support will open in July.

Allowing you and your clients to engage with us well ahead of time to understand what we expect and pinpoint where more work is needed.

Please take advantage of these resources.

We'd rather offer training tips than watch firms stumble and fail to reach the finishing line. That wastes your resources and ours.

As part of this, we are also keen to hear from you.

We have listened to feedback received and adapted – PASS is an example of this.

But we know we still have more to do.

And feedback that helps us provide what firms need to cross the finishing line really matters to us.

Conclusion

When runners cross the finish line on Sunday, it will be because they did the work – and believed in the value of doing something properly.

Finishing the marathon would be far less satisfying if the course was 2 miles rather than 26.2!

Our authorisation process is similarly demanding. It's meant to be.

But for firms that come prepared – and with the right support behind them – it doesn’t have to be agony.

That’s what we’re asking of you: Be the support firms need, when they need it.

By setting boundaries, holding your clients to high standards – even when it’s difficult – and taking the long view.

When we get this right together, we protect consumers. Help set firms up for success. Support a market the UK can be proud of.

And show all those thinking of running next year that doing it properly is always worth it!