Fintech
Do I need FCA authorisation to build a fintech?
Most founders asking this do not need their own authorisation. They need to understand one regulation, its limits, and what it costs them in control. The pages selling the alternative rarely spell any of that out.
The two roles, and the test before them
Open Banking has two regulated activities, both in Schedule 1 of the Payment Services Regulations 2017: payment initiation services at paragraph 1(g), and account information services at paragraph 1(h). One moves money on the customer’s instruction; the other reads their account data.
The gate before either is in the same Schedule: these are payment services when carried out “as a regular occupation or business activity”. Two edge cases from the FCA’s own guidance are worth knowing because they decide real products:
- It is not account information if the only thing shown to the customer is their name, account number and sort code. It can be, even for a single account.
- A firm that passes card details and a payment order but never comes into possession of personalised security credentials is not carrying out payment initiation.
The answer most people actually need: become an agent
Regulation 34 is titled “Use of agents”. An authorised payment institution, a small payment institution or a registered AISP can appoint you as its agent, and you then provide its payment services under its permissions.
Note the FCA’s word. This is an agent, not an appointed representative — that is a different regime under different legislation, and using the wrong term in a conversation with a provider or an investor marks you out immediately.
| What the agent route gives you | What it costs you |
|---|---|
| No authorisation, no capital requirement, no application fee of your own | You must be on the Financial Services Register before you provide anything |
| Live far sooner than an application allows | You can only provide your principal’s services — you cannot provide or purport to provide AIS or PIS in your own right |
| The principal carries responsibility for your acts and omissions | The customer agreement is with the principal, not you, and it must be clear to the customer that you act as their agent |
| Each principal registers you separately | Your principal must hold professional indemnity insurance covering its agents’ services too |
That third row is the one to think hardest about. If the contractual relationship for the regulated part of your product sits with your provider, you have a commercial dependency that is difficult to unwind later. It is the right trade for most companies at the start and the wrong one for some.
Or stay out of scope entirely
There is a second route the FCA describes: a technical service provider, which obtains and processes payment account information to support an authorised firm but does not provide the information to the end user itself. There is no direct relationship with the consumer, and such firms do not need to be authorised or registered.
The line is narrow. The exclusion covers firms that “simply provide IT support”, and the FCA says in terms that providers of payment initiation or account information services are not technical service providers. If your product shows the data to the customer, you are not this.
If you do apply: the real numbers
| Route | Initial capital | Application fee |
|---|---|---|
| Registered AISP — account information only | None | £1,130 |
| Authorised PI — payment initiation | €50,000 | £2,820 |
| Authorised PI — money remittance | €20,000 | £2,820 |
| Authorised PI — other payment services | €125,000 | £5,640 |
Two things about that table. The fees took effect on 2 July 2026. And the capital figures are stated in euros in the Regulations, with no sterling equivalent published — so anyone quoting you a pound threshold has converted it themselves.
A registered AISP has no capital requirement but must hold professional indemnity insurance. And registration only covers account information: want anything else alongside it and you are applying for full authorisation instead.
How long it takes, honestly
Median calendar days to determination. Lower quartile 113, upper quartile 238. Against a statutory deadline of three months — which only begins once the FCA treats the application as complete.
That gap between the statutory three months and the observed median is the most useful thing on this page. The Regulations give the FCA three months from a completed application and twelve months as an outer limit regardless. The published performance data shows the median case taking the best part of six.
You will read elsewhere that the FCA takes “up to six months”. That figure comes from a different regime. Plan from the FCA’s own numbers, and assume the completeness question is where the time goes.
Is the market actually there?
Open Banking Limited reported 40.16 million payments in June 2026, of which 7.73 million were sweeping variable recurring payments, and more than a billion payments and a hundred billion API calls cumulatively. Two caveats worth carrying, because almost nobody repeats them:
- The cumulative figures cover the nine largest banks, not the whole market.
- The user counts are connections with reporting brands. Open Banking Limited states it cannot identify people using more than one brand, so the headline user number is not a count of people.
On commercial variable recurring payments: these are now live through a scheme operated by the UK Payments Initiative, a company formed by a group of firms and supported by the FCA, which launched in 2026. The FCA has said it will consult on a long-term regulatory framework by the end of 2026, so this part of the landscape is still moving.
Sources. Regulated activities and definitions: Payment Services Regulations 2017, Schedule 1 and regulation 2(1). The agent regime: regulation 34, the FCA Handbook PERG 15.3 and 15.4, the FCA’s page on agency models, and the FCA’s Payment Services and Electronic Money approach document, version 8, May 2026. Capital: Schedule 3, Part 1. Fees: FEES 3 Annex 8R and Annex 1AR as replaced by the Periodic Fees (2026/2027) and Other Fees Instrument 2026, in force 2 July 2026. Determination deadline: regulation 9, applied to registration by regulation 19. Performance: FCA authorisations operating service metrics 2025-26 Q3. Volumes: Open Banking Limited, July 2026 and its API performance page. All retrieved 9 October 2026. This is a description of published material, not regulatory advice.
Working out whether you are in scope?
The answer usually turns on one or two details about what the product actually does with the data or the money. Describe it and I will tell you which route you are looking at.
Start here →