International wholesale firms looking to undertake business in the UK

We are committed to the UK having a competitive and open financial system. International firms are an established part of the UK's financial services landscape and help the UK to maintain open markets. 

If an international firm meets the requirements to be authorised, including having good risk mitigation in place, then we expect to authorise it. 

Review our approach to international firms in detail before starting your application.

Minimum standards for authorisation

Firms that wish to be authorised in the UK need to meet the minimum standards set out in the relevant legislation.  For wholesale markets firms this is likely to be the Financial Services and Markets Act 2000 (FSMA), which means that such firms will need to satisfy the Threshold Conditions. Applications for other activities will have to meet other criteria, which in most cases will be similar to the Threshold Conditions. 

The five Threshold Conditions are: 

• COND 2.2 Location of Offices (only applicable if the firm chooses to incorporate in the UK)
• COND 2.3 Effective Supervision
• COND 2.4 Appropriate Resources
• COND 2.5 Suitability
• COND 2.7 Business model.  

When deciding whether to authorise an international firm, we apply the same standards with the same statutory objectives in mind as for UK firms. Once authorised, firms are expected to meet the minimum standards at all times (and the FCA is empowered to take action if they fail to do so). 

Find out what we expect from international firms. 

We provide guidance on the ‘Threshold Conditions’ in the section of our Handbook called COND.  They require an assessment of (non-exhaustively): 

• The viability of your business model.
• Whether you will be carrying on business in the UK.
• Whether you have appropriate financial and non-financial resources for your business model.
• Whether the people running your business are fit and proper.
• Whether there is anything about your firm which may prevent us from supervising you effectively or which makes us concerned about the risk of financial crime.  

When you need to be authorised

‘FSMA’ activities are activities regulated by us under the Financial Services and Markets Act. These are explained in more detail in the Regulated Activities Order (RAO).   

Sections 13.1 to 13.5 of the Perimeter Guidance Manual (PERG) provide some answers to common questions on whether firms fall within MiFID and how their permissions may correspond to those in MiFID. 

If your firm is based in the EU, you can see how the activities in the RAO might be mapped to the MiFID activities in our PERG sourcebook in the table in PERG 13 Annex 2 Annex 2. 

Requirement to have a UK presence

International firms have a degree of choice on the legal form of their UK presence. For example, they can serve UK customers from an entity incorporated outside the UK or within the UK. 

Where a firm seeks authorisation, the FCA will authorise the whole firm, including its UK and overseas offices, and we expect it to have an establishment or physical presence in the UK and our assessment will extend, as required, to the entire firm. 

We need to ensure that we will be able to supervise you effectively and take such action as we consider appropriate if we become aware of potential harm. Firms will therefore need to satisfy us that they are structured in a way that will enable us to do so. Read more about how we assess risk of potential harms. 

Our guidance doesn't cover every business model or scenario, and there may be additional factors that your firm needs to consider.