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Is the FCA getting easier to deal with?

Is the FCA getting easier to deal with?

What the FCA's 2026 survey reveals about firms' experiences, approval times and reporting demands, plus practical implications for payment-business deals.

Regulation
By Rodolfo Basilio 9 min read 6 October 2026

Its latest survey shows stronger relationships with firms, alongside frustration over approval times and reporting demands.

Firms reported a better relationship with the Financial Conduct Authority (FCA). Whether dealing with it requires less effort deserves a closer look.

The FCA’s survey release on 2 October 2026 [1] brings those questions into focus. It provides a reason to examine the experience of regulation, whether you run a financial business, work in one or follow the sector.

The responses were collected between January and April 2026. They describe earlier experiences and cannot establish how quickly an application submitted today will progress. Keep that timing in mind when reading the findings below. [2]

Our view is that progress should be judged through clearer requirements, less repeated work and a better understanding of what happens next. Those are useful tests for everyday operations, with additional implications when a business changes hands.

What has improved in firms’ relationship with the FCA?

A larger share of firms gave their overall relationship with the regulator a high satisfaction score.

Among full-permission firms in the survey, 79% rated the relationship at least 7 out of 10, compared with 74% in 2025. The 2026 question covered 4,064 firms and asked about their dealings with the FCA over the preceding 12 months. [2]

The Payments & Retail Banking group was more positive than the overall result: 85% gave that rating, from a group of 271 respondents. This combines payment firms and retail banks. The report does not separate small payment institutions, authorised payment institutions or electronic money institutions. [2]

The survey method changed in 2026. The researchers adjusted and tested year-on-year comparisons, so the published satisfaction comparison remains usable. Some other questions cannot be compared directly. [3]

What did firms say about FCA authorisation?

Most firms with relevant experience gave positive answers. The time involved attracted the strongest negative response among the aspects tested.

The findings below concern 1,451 full-permission firms with experience of the authorisation process in the preceding 12 months.

Aspect of the process Firms agreeing
What the FCA required was clear 74%
The FCA was helpful 70%
The process was straightforward overall 66%
The time involved was reasonable 66%

On timing, 20% disagreed. [2]

The survey used a broad definition of authorisation experience. It included changes to permissions, senior-manager applications, changes in control and other processes. The timing figure therefore cannot be presented as a separate result for payment institutions or acquisitions. [2]

It also records whether firms considered the time reasonable. It does not show that the FCA missed a statutory deadline in those cases, or explain the cause of each difficult experience.

What do actual FCA decision times show?

Historical processing data adds another perspective. It measures decisions, while the survey records how firms felt about their experience.

For 2025/26, the FCA reported deciding 99.9% of change-in-control cases within its 60-working-day timeline. One case missed the target because of an operational error. [4]

Its separate timing tables cover FSMA firms, meaning firms authorised under the Financial Services and Markets Act. These are not payment-institution-specific benchmarks.

Financial year 25% decided within Median: 50% decided within 75% decided within
2025/26 18 days 39 days 67 days
2024/25 14 days 34 days 62 days
2023/24 24 days 50 days 83 days

These are calendar days, from receipt of a notification, complete or incomplete, to the decision. They include time spent obtaining missing information. [5]

The reported timings improved against 2023/24 but increased against 2024/25. They provide historical context, not a forecast for an application submitted today.

Why did information requests attract criticism?

Some respondents questioned the effort involved in supplying information and how that information was used.

Their comments included repeated requests, perceived duplication and unclear explanations of what happened to the data afterwards. These are firms’ reported concerns; the survey does not independently establish that every request they questioned was unnecessary. [2]

The Financial Resilience Report, FIN073, was the most frequently named request among those answering a follow-up about requests they considered unnecessary. That follow-up was directed at firms that had already expressed concern about the volume of requests. It was not a vote by all surveyed firms to remove the return. [2]

For a firm giving feedback, a specific example is more useful than a general complaint. Identify the return, the unclear instruction and the work involved. Keep an apparent duplicate request separate from information that is simply difficult to retrieve internally.

Have reporting requirements changed since these experiences?

FIN073 has changed since some of the experiences captured in the survey. A longer deadline, a different reporting frequency and less work are separate things.

From 1 April 2026, its submission window increased from 20 to 30 business days after the relevant reporting reference date. [6]

Annual reporting has two conditions. The firm must have submitted Section A of the Retail Mediation Activities Return (RMAR) in the last reporting period of its previous financial year. Its reported revenue from regulated activities within RMAR’s scope must not have exceeded £150m for that year. Other firms within FIN073’s scope remain quarterly reporters. Both schedules have a 30-business-day submission deadline. [7]

From 1 October, guidance clarified instructions for annual and quarterly reporting. It did not expand annual eligibility. [8]

More time to submit does not establish how much work a return takes to prepare. Firms need to check which change applies to them before assuming a saving.

What changed for payment and e-money firms after the survey?

The supplementary safeguarding rules took effect on 7 May 2026. Safeguarding means protecting relevant customer funds. The changes include monthly reporting and resolution-pack requirements for institutions within scope. A resolution pack holds information to help return customer funds if the business fails. [9]; [10]; [11]

Annual safeguarding audits have their own scope and exemptions, including a £100,000 relevant-funds test with conditions on the period assessed. Small payment institutions can elect to safeguard, but that does not automatically make the audit mandatory. [12]; [13]

First audit reports may not yet be due under the transitional arrangements. Check the firm’s duties and reporting dates before treating an unavailable report as a missing filing. [13]; [14]

The survey cannot measure experience after these rules took effect. Preparation may have influenced responses, however: the policy was published in August 2025. [9]

How can firms judge whether dealing with the FCA is easier?

We suggest looking at clarity, effort and predictability separately.

Clarity: Did staff understand what was needed and what remained unresolved?

Effort: What information had to be collected, checked or recreated?

Predictability: Which dates were confirmed, which were estimates and which depended on another decision?

This is a suggested management approach, not an FCA reporting requirement. Record a specific example behind each concern so the team can identify where the difficulty sits.

What does this mean when buying or selling a payment business?

Prior FCA approval applies to relevant acquisitions or increases in control of small and authorised payment institutions (SPIs and APIs), and small and authorised electronic money institutions (EMIs).

Reaching or passing relevant thresholds of 10%, 20%, 30% or 50% can trigger approval requirements. Shares, voting rights, indirect holdings and significant influence need consideration. Completing a relevant acquisition without approval may be a criminal offence. [15]

The assessment period is 60 working days from acknowledgement of a complete notification. The FCA can interrupt it once for further information: normally up to 20 working days, rising to 30 in specified cases. Allow separately for preparation and completion; questions can also arise during assessment. [16]; [17]

Our recommendations are:

  • Buyers: prepare the business plan, ownership information and funding evidence early. Required criminal checks for individual controllers and beneficial owners must be no more than six months old when notifying the FCA. Check funding conditions and expiry dates against the specific timetable. [17]
  • Sellers: agree evidence and progress milestones before granting or extending exclusivity. Assemble applicable FIN073 and safeguarding returns, available audit reports and details of audit arrangements and due dates.
  • Both sides: ask the transaction solicitor to document the long-stop date, extensions and each party’s rights if completion remains outstanding.

Preparation can reduce avoidable delays. It does not guarantee faster approval or establish a standard completion date.

Vertice Fintech brokers UK SPI and API sales and acquisitions. For a transaction-specific discussion, speak to Rodolfo Basilio.

Frequently asked questions

What is the FCA and Practitioner Panel survey?

It records regulated firms’ views of their relationship with the FCA and aspects of its work. The 2026 findings were released on 2 October, following fieldwork between January and April. [1]; [2]

Does the survey show that the FCA is easier to deal with?

It supports a better overall relationship with full-permission firms. Whether a particular task is easier needs a closer look: views on authorisation timing and reporting were more mixed. The findings do not measure every firm’s current experience. [2]

Does 20% dissatisfaction mean the FCA missed its deadlines?

No. The figure describes disagreement that authorisation timing was reasonable among firms with relevant experience. It is not a measured rate of missed statutory deadlines. [2]

Are the authorisation findings specific to payment businesses?

No. The published aggregate combines full-permission firms across sectors and several processes. It cannot be used as a payment-sector or change-in-control-only result. [2]

Why does FIN073 appear in the discussion?

It was the most frequently named information request among respondents answering the unnecessary-request follow-up. Current reporting requirements need checking separately because rules and guidance changed during and after the survey period. [2]; [7]

Does every firm now submit FIN073 annually?

No. Eligibility requires RMAR Section A submission in the last reporting period of the previous financial year and reported regulated revenue within RMAR’s scope of no more than £150m for that year. Other in-scope firms report quarterly. October’s guidance did not widen eligibility. [7]; [8]

When does the change-in-control assessment period start?

The 60-working-day period starts when the FCA acknowledges a complete notification. An interruption for further information may extend it. Preparation and completion need separate allowances; this is not the full transaction timetable. [17]

What can a firm do with these findings?

Use them to review its own experience of clarity, staff effort and uncertain dates. Our recommendation is to keep specific examples and separate confirmed requirements from assumptions when planning work or discussing concerns with the regulator.

Sources and references
  1. FCA’s survey release on 2 October 2026; FCA release
  2. Survey report, p11; Survey report, Figure 2.1, p17; Survey report, Table 3.1, p59; Survey report, Figure 2.15, p41; Survey report, p40, footnote 9; Survey report, pp38–40; Survey report, p38; survey report, p11; Survey report; Survey report, Figure 2.15; Survey report, pp40–41
  3. Methodological note, pp19–22
  4. FCA service metrics, published July 2026
  5. FCA OE-M05, published July 2026
  6. Handbook Notice 139, sections 2.29 and 3.134
  7. SUP 16.30.7R–8AR; current FIN073 rules; Current FIN073 rules
  8. Handbook Notice 144, sections 3.189–3.190; Handbook Notice 144
  9. FCA PS25/12; PS25/12 publication record
  10. monthly reporting rules
  11. resolution-pack rules
  12. CASS15.1
  13. SUP3A.1; SUP3A.9
  14. transitional provisions, rows 3D–3E
  15. FCA Approach Document, paragraphs 4.21–4.30
  16. FSMA, sections 189–190
  17. FCA notification guidance; FCA submission requirements
Rodolfo Basilio · Founder, Vertice Fintech
Portrait
Rodolfo Basilio
Founder, Vertice Fintech
London · 2026
About Rodolfo

Inside the UK fintech regime, since 2007.

Rodolfo Basilio has been in the UK fintech business since 2007, operating inside the same regulatory regime he now advises on. He founded Angra in 2010 and exited in 2022. He co-founded Remitec in 2018 and exited in 2022. Vertice Fintech is where that operator experience is now put to work for a small number of vendors and acquirers each year.

"The best transactions look boring on the outside. That is the point."

Rodolfo Basilio · Founder, Vertice Fintech
Founded
Vertice, 2007 · London
Prior
Angra · Remitec
Remit
SPI · API · EMI
Based
London · FCA regime
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