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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.”

Shorter Statutory Deadlines

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


FCA Voluntary Deadlines

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."

PRA Voluntary Deadlines

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.

L-Plate Licenses

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.

Review of Regulatory Principles and “Have Regards”

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. 

 
Rationalising Reporting Requirements:

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. 

At a glance...

Publication link 

https://assets.publishing.service.gov.uk/media/68760c18a8d0255f9fe28e51/Regulatory_Environment_Pillar_Cross-Cutting_Issues_Consultation.pdf 


FCA sets faster targets for authorisations | FCA


FCA letter to the Chancellor: KPIs and metrics for authorisations processes


Speed of regulatory approvals

Published date

15 July 2025

Who has published it?

HM Treasury

Publication type

Consultation

Any key dates?

  • 9 September 2025 - Consultation closes (midday)

  • Late 2025 - 2026 - Government response and potential legislative proposals

  • 2026 onwards - Implementation of reforms (subject to legislation and regulator readiness)

What's it relevant to?

  • Banks

  • Motor finance firms

  • Payment firms

  • E-money firms

  • Insurance

  • Building societies

  • Financial services providers

  • Fintechs


Authors: Catherine MacPherson and Nikesh Shah

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at July 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.

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Date published
24 Jul 2025

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