A&O Shearman | FinReg | UK provisional licences authorisation regime
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  • UK provisional licences authorisation regime

    4 December 2025
    The UK's Treasury has published a policy update on creating a provisional licences authorisation regime for early-stage financial services firms seeking FCA authorisation. The purpose is to reduce the barriers that financial services firms face when seeking authorisation. The proposed "provisional licences" regime will enable the FCA to grant time-limited permissions (generally up to 18 months) so that firms can get "up and running" in a controlled environment with strong regulatory oversight, whilst working towards full authorisation. The policy update sets out details of how the government intends to deliver this. It discusses the purpose and design of the regime including its scope and eligibility, the duration of provisional licences and other restrictions and requirements on firms during the provisional licence period. It concludes with a discussion of exiting the regime, ideally with full authorisation. This provisional licence regime will require primary legislation, and the updates reports that the government will take this forward when parliamentary time allows. The FCA will engage with industry on the design of the regime and consult as necessary.

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