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Investment & wealth
Investment and wealth management authorisation
Authorisation for wealth managers, asset managers and investment firms — investment services, fund management, the prudential position and the governance a regulator expects before granting permission.
We take investment and wealth firms through authorisation to fully operational — the regulatory pack, the prudential position, client-asset protections and the governance a regulator expects to see before granting permission.
Investment applications are decided largely on two things: whether the permission profile matches what the firm will actually do, and whether the people running it have the capacity and competence to do it. Firms routinely apply for broader permissions than they need, which invites questions about controls they have no intention of building, or narrower permissions than the business model requires, which surfaces six months later as a variation of permission. Getting the profile right at the outset is the single highest-leverage decision in the process.
Who we do this for
- Discretionary wealth and portfolio managers
- Financial advice firms and planning businesses
- Digital wealth, model-portfolio and platform propositions
- Asset managers and fund managers, including first-time AIFMs
- Corporate finance and capital markets advisory firms
- Brokers and firms dealing on a matched principal basis
Permission profile and the exemptions worth knowing
Portfolio management, advising, arranging, dealing as agent and dealing as principal each carry different capital and conduct consequences. Article 3 exemption remains available to some advisory firms and materially reduces the prudential burden, but it constrains what you can do. Matched principal dealing is treated differently from dealing on own account. And whether you will hold client money or safeguard client assets changes the application more than almost any other single answer.
IFPR, ICARA and own funds
Under MIFIDPRU, your own-funds requirement is the highest of the permanent minimum requirement — £75,000, £150,000 or £750,000 depending on activities — the fixed overheads requirement, and where applicable the K-factor requirement. The ICARA process sits over that: harms identification, capital and liquidity adequacy, and a wind-down assessment. New firms are expected to arrive with an ICARA document that reflects their actual business rather than a template, and the wind-down section is now examined closely.
Client assets and client money
If you touch client money or hold custody assets, CASS obligations follow: segregation, acknowledgement letters, internal and external reconciliations, a CASS resolution pack and a named individual responsible. Many wealth propositions can be designed to avoid holding client money at all by routing through a third-party custodian — a decision worth taking deliberately at the design stage rather than inheriting from an operating model.
Fund management and the AIFM threshold
Below the AIFM thresholds you may register as a small AIFM, which is a substantially lighter regime but restricts marketing and passporting. Above them, full-scope authorisation brings depositary requirements, remuneration rules, and detailed reporting. Managers who expect to cross the threshold during the life of the first fund should plan the transition rather than be caught by it.
Where we authorise
United Kingdom
Investment firms, wealth managers and fund managers under the FCA.
European Union
MiFID firms and fund managers, with EEA passporting.
Rest of world
Fund and asset-management regimes in major hubs.
How the process runs
Permission profile and structure
What the firm will actually do, which permissions that requires, whether an exemption applies, and whether the ownership chain will clear the controller assessment.
Building the pack
Regulatory business plan, compliance and risk frameworks, ICARA and financial model, client-asset and conflicts policies, SMCR governance map and individual applications.
Submission and case officer
Six months for a complete application, twelve for an incomplete one. Expect scrutiny of the ICARA, the wind-down analysis and the capacity of named senior managers.
Getting operational
Governance running, ICARA on a review cycle, client-asset controls tested, reporting diarised and the investment process documented as described.
Common questions
How long does FCA authorisation take for an investment firm?
Six months for a complete application, twelve for an incomplete one. Most investment firm applications complete within six to nine months of submission, with two to three months of preparation before that.
What capital does a new investment firm need?
Under MIFIDPRU, the highest of the permanent minimum requirement (£75,000, £150,000 or £750,000 depending on permissions), the fixed overheads requirement, and the K-factor requirement where it applies. The fixed overheads requirement often binds for smaller firms, so the cost base drives the capital number more than the permission does.
Do I have to hold client money?
No — many wealth and advisory propositions are structured so that client money and custody sit with a third-party custodian. Avoiding CASS obligations meaningfully reduces both the application burden and ongoing cost, but it has to be designed in deliberately.
What is ICARA and when do I need one?
The Internal Capital Adequacy and Risk Assessment process is the core prudential document under IFPR. It identifies the harms your business could cause, assesses capital and liquidity adequacy against them, and sets out a wind-down analysis. New applicants are expected to submit one that reflects their own business model.
Small registered AIFM or full-scope?
Below the AIFM thresholds, small AIFM registration is significantly lighter but restricts marketing and passporting. Full-scope authorisation brings depositary, remuneration and reporting obligations. If you expect to cross the threshold during the first fund, plan the step up in advance.
More on how we work, fees and timelines is on the FAQ page, and the regimes we cover are set out under jurisdictions.
Why firms use Pitchsd
We have sat inside investment firms as well as writing their applications — running compliance, chairing risk, and defending an ICARA and a wind-down plan to a case officer who had read it properly. Our regulatory business plans describe how a firm will genuinely operate, which is why they hold up under questioning.
We also build the technology the business runs on, so the platform and the permission arrive together rather than being someone else's problem. And we can put senior people into the business — a fractional MLRO, non-executive directors, a CFO — through our network. Get in touch to talk through where your application stands.