
Leeds Reforms: FS Sector Strategy: Cross-Cutting Reforms and Speeding Up Regulatory Approvals
What’s this about?
HM Treasury has published a consultation on cross-cutting reforms as part of the government’s Financial Services Growth and Competitiveness Strategy. The cross-cutting reforms are intended to ensure that the regulatory framework in the UK remains effective and proportionate. Once the consultation closes legislation will be required to implement a number of the changes.
Catherine MacPherson, a Managing Associate in our Financial Services Regulatory team says:
“We’re regularly asked how long applications to the FCA will take. The proposed statutory and voluntary changes could have a real impact on business planning and momentum in the financial services sector.”
In the consultation the government proposes setting new shorter deadlines for applications in relation to new firm authorisations, variation of permissions and senior manager applications. The government believe that quicker decisions will make the UK more attractive however firms may be concerned that a faster turnaround results in a higher rejection rate.
The government is suggesting the proposed statutory deadlines in the consultation:
Application Type | Current deadline | Proposed change |
New firm authorisations |
6 months Complete application | 4 months |
12 months Incomplete application | 10 months | |
Variations of permission |
6 months Complete application | 4 months |
12 months Incomplete application | 10 months | |
SMCR approved persons | 3 months | 2 months |
At the same time the FCA announced that they will voluntarily reduce other targets. The Chief Executive of the FCA sent a letter to the Chancellor on 15 July 2025 setting out the voluntary targets the FCA intends to implement. Some of these targets are specific to firm and business type. We’ve pulled them together with the statutory targets to highlight the differences.
Application Type | Current deadline | Proposed statutory change | Voluntary |
Payments and e-money firm authorisations and registrations | 3 months Complete application | none | 3 months |
12 months Incomplete application | none | 10months | |
Variations of permission where the new permissions closely align to the existing business model | 6 months Complete application | 4 months | 3 months |
12 months Incomplete application | 10 months | 6 months | |
SMCR approved persons | 3 months | 2 months | At least 50% in 35 days |
The FCA acknowledge that these will be stretch targets. Perhaps pre-empting the concerns firms may have about higher rejections the FCA Chief Executive stated that:
"For all types of application, we will continue to enhance how we communicate with firms and individuals during the application process and provide regular and transparent feedback about progress. We will also consider how we can further enhance our support services to help improve the quality of the application materials that firms submit, as this is an important contributor to the length of time to process an application."
The PRA also announced that they will voluntarily reduce other targets. The Chief Executive of the PRA sent a letter to the Chancellor on 15 July 2015 which includes the following voluntary targets in addition to the proposed statutory targets:
Application Type | Current deadline | Proposed statutory change | Voluntary |
Insurance firms that qualify for the whole sale insurance accelerated authorisation pathway | 6 months Complete application | 4 months | 3 months |
12 months Incomplete application | 10 months | - | |
New authorisation for insurance SPVs | 6 months Complete application | 4 months | 6 weeks |
12 months Incomplete application | 10 months | - | |
New authorisation for insurance SPVs that qualify under the accelerated pathway in CP15/24 | 6 months Complete application | 4 months | 10 working days |
12 months Incomplete application | 10 months | - | |
SMCR approved persons | 3 months | 2 months | At least 50% in 45 days |
The PRA acknowledges that when they “start that reporting some new targets may not be met immediately, as it will take time to make the necessary changes” they are however “committed to transparently showing the progress being made towards delivering these important reforms.”
The government is considering a new streamlined authorisation regime for start-ups that would see them being given L-plates / provisional licences. The government will consult on this proposal in the autumn.
The government propose to legislate, when Parliamentary time allows, to change the way that “have regards” operate. They intend to remove the requirement to consider each “have regard” when regulators make day-to-day decisions. Regulators would instead need to have regard to the regulatory principles and remit letter when producing their new long-term strategies. The government believe this will allow regulators to be more agile.
The government are also consulting on streamlining requirements between the overarching framework (under the Legislative and Regulatory Reform Act 2006 and the accompanying Regulators’ Code of Practice) and the FSMA framework. The intention being to remove overlap for the FCA and PRA in delivering their core responsibilities.
The government acknowledges the burden on regulators following the increase in reporting documents since 2013. The government is asking which documents published by the FCA and PRA are found to be most helpful and the information considered most important. The government is open to reducing reporting that creates unnecessary burdens. They are also seeking to improve effective scrutiny.
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