What Does ‘ready, willing, and organised’ Mean?

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When applying for FCA authorisation, one of the key phrases you’ll encounter is “ready, willing, and organised.” But what does this actually mean, and why is it so important for your application?

In this blog, we’ll break down the FCA’s expectations, explore how to demonstrate that your firm meets these criteria, and provide practical tips to ensure your application is successful.

Understanding the FCA’s “Ready, Willing, and Organised” Requirement

The Financial Conduct Authority (FCA) uses the term “ready, willing, and organised” to assess whether a firm is fully prepared to operate in a regulated environment. This requirement is outlined in the FCA Handbook, specifically in the Threshold Conditions section: COND 2.3. These conditions are the minimum standards firms must meet to become, and remain, authorised.

Ready

The FCA expects you to apply for authorisation when you are at the stage that if the FCA authorised you, you can start trading immediately. Your firm must have the necessary resources, systems, and controls in place to carry out the regulated activities you’re applying for. This includes having the right people, technology, and processes to comply with FCA rules from day one.

This often creates a conundrum for firms, as you may be waiting for contracts and funding to be secured, pending FCA authorisation. This can create financial strain, especially when attracting investors who may hesitate to commit capital before regulatory approval is confirmed. Additionally, the FCA approval times don’t help the situation and contracts can be left pending for a while.

The unfortunate reality is that many of these costs must be fronted early on. We break down some aspects and ‘get arounds’ below.

What Do You Need To Do To Get Ready?

Research your product and market, and evidence compliance with Consumer Duty.
Read the FCA website and understand what it expects of you.
Map your activity to the right FCA permission needed. The FCA expects you to have thought about exactly what permissions you need, including whether you are a Limited or Full Permission firm. We can help you with this.
Prepare all submission documents. There are a number of documents to prepare, including a regulatory business plan, financial forecasts, a suite of compliance policies as well as documents and checks for the individuals running the firm. Again, we can assist with completing these using our templates.
Have all policies and procedures in place as final versions.
Ensure policies are distributed to staff and that they understand the contents.
Employ staff with skill, knowledge and experience to undertake the regulated activity.
Have appropriate operational infrastructure in place such as IT and technology. If you aren’t a limited permission firm, you can expect the FCA requesting demos and screenshots.
Have required funding in place. For a limited permission firm the key test is meeting debts as they are due. For other permissions, there may be minimum capital requirements.
Secure a head office and key hires in the UK.
Secure a PII quote.
Draft your outsourcing agreements, and detailing who your introducers are; along with due diligence for both.

Managing Upfront Costs When Seeking FCA Authorisation

Here are some strategic ways to minimise upfront costs while meeting FCA expectations:

1️⃣ Key Areas Where You Can Delay Costs

Although significant investment is required, some financial commitments can be deferred until closer to your authorisation date. Here are some areas where you can save:

Client Bank Accounts (If applicable to your model)

Many banks require firms to be FCA authorised before issuing a segregated client bank account.
This means you can have your banking agreements in place but delay activation until authorisation is granted.

Technology & White-Labelling Solutions

If you are using a white-label technology provider, you may not need a fully functional system immediately.
Instead, you can develop a BETA version of your platform and have all technical agreements prepared in principle.
The FCA expects a clear demonstration of how your tech operates, but it does not need to be live at the time of application.

Professional Indemnity Insurance (PII)

Insurance is often a mandatory part of FCA authorisation, but the policy doesn’t need to be active upfront.
Many insurers will provide a quote and confirm coverage in principle, allowing you to finalise the policy later.

Capital Resource Requirements

The FCA requires certain firms to maintain a minimum level of capital, but in many cases, you can deposit the full amount just before authorisation.
The specific amount depends on your regulatory permissions, but firms often have flexibility in how and when the funds are made available.

2️⃣ Investor Considerations & Regulatory Expectations

Start-up financial services firms often operate at a loss for the first few years, relying on investment capital rather than immediate profitability. The FCA recognises this but expects you to:

Demonstrate financial sustainability by passing the “cash flow test” and “balance sheet test.”
Showcase adequate funding sources to cover operational losses until the business becomes self-sufficient.
Provide clear financial projections that illustrate how the business will meet capital and liquidity requirements over time, allowing room for growth and also stress-testing.
If your firm is part of a group, and requires funding from a parent, the FCA may inquire into this and how the arrangement will work.

💡 Key Takeaway: While investors may be reluctant to commit funding pre-authorisation, your ability to present a solid financial and regulatory strategy will increase your credibility and de-risk their investment.

Willing

The FCA will consider how you act during your interactions with them. The FCA wants to be confident that you are being open and honest in all your dealings with them.

If the FCA asks for more information, this means:

You are proactive in getting back to them.
Make your staff available to deal with enquiries promptly.
Provide requested policies and procedures promptly.
You must also ensure to disclose all relevant details related to criminal, civil, regulatory, and business dealings.

The FCA will require some policies as part of submission, but can request to see any that you should have in place as part of compliance of FCA rules.

When the FCA queries aspects of the application submission, they give a very short window to respond, usually 5 – 10 working days. We ask that you forward any correspondence to us immediately, so that we can plan the response.

Whilst some changes can be expected during the application process, the FCA has explicitly said that you cannot submit a poor application but be willing to, with their help, to address the deficiencies.

Organised

Your firm must structure its operations to ensure effective governance, oversight, and accountability. This includes having clear reporting lines, defined roles, and robust risk management frameworks.

Essentially a reiteration of the points above, the FCA will consider:

Why you are applying now; and
If the FCA were to grant your authorisation today, can you immediately carry out the activity you applied for, or is there something missing that still needs to be addressed?

The Application Process

1. Contact Us to discuss what permissions you need. We’ll help you map your activities to the right regulated permissions. Getting this right is important to avoid delays.
2. Prepare the application documents: We provide templates and have regular discussions with you to complete the required documents. We also help prep you for FCA interactions, for example a mock FCA call.
3. Submit Application: Once you are ready, willing and organised, we will submit the application. This also includes completing the application form on the FCA portal, called ‘Connect’. You will then go in and pay the FCA application fee.
4. Support until FCA decision is made: We are on hand for any questions and queries from the FCA. Send over any questions to us straight away and we will have a call with you to discuss and plan answers.
5. FCA decision: You are approved – Great! You can start trading. If you are not approved, don’t worry it is not the end. We are on hand to discuss next options, whether that’s a resubmission with no additional fees from us, or on a reduced rate.