Most guides to FCA authorisation read like a shopping list: initial capital, a safeguarding methodology, fit and proper directors, a business plan. Firms tick every box on that list and still watch their application stall for months, get pulled back for repeated information requests, or get withdrawn before a decision is ever made. The gap between "we submitted everything required" and "we got authorised" is where most of the real story about FCA EMI application rejection reasons actually sits.
In September 2025, the FCA published something unusually direct for a regulator: a document naming, in plain terms, the patterns it sees across authorisation applications that fall short. Read alongside its 2025 findings on safeguarding and wind-down planning, it gives a clearer picture than any generic checklist of why e-money and payment permission applications fail, and what separates a firm that gets through the gateway from one that doesn't.
What the FCA's 2025 review says is really failing
In September 2025, the FCA published guidance on common failings in authorisation and registration applications. The issues fell into three main areas: *staffing, policy documentation, and financial resourcing.
Staffing
The problem isn't a lack of qualified people. Instead, firms often rely too heavily on external compliance consultants. When questioned, business leaders themselves struggle to explain their regulatory obligations. The FCA is clear: firms remain responsible for their own applications, and it expects the people running the business—not just consultants—to be able to answer questions.
Policy Documentation
Many applications use template policies that haven’t been tailored to the firm. Common weaknesses include:
- Policies that simply repeat FCA rules instead of showing how the firm will apply them
- Documents that don't connect
- Vague IT infrastructure descriptions that make delivery timelines impossible to assess
These look complete at first glance but fall apart under FCA scrutiny, making them one of the most frequent reasons for rejection.
Financial Resourcing
Here, the failings are more mechanical:
- Missing historic accounts
- Inaccurate financial data that triggers repeated information requests
- Weak evidence that prudential requirements will actually be met, rather than just modelled on paper.
Safeguarding and wind-down planning: where the gaps turn into firm failures
Safeguarding remains one of the Financial Conduct Authority’s (FCA) toughest areas of oversight, and the rules have evolved quickly. Under PS25/12, new requirements took effect on 7 May 2026. These include:
- Daily reconciliation of safeguarded funds
- Annual independent audits of safeguarding practices
- Monthly reporting to the FCA
- A resolution pack that must be ready at short notice
- Any system designed around pre-2026 standards is already outdated.
Wind-down planning shows similar weaknesses. In a 2025 review of 14 e-money and payment firms, the FCA found none fully met expectations. Common issues included:
- Risk appetites that didn't reflect actual business activities
- Liquidity risks judged informally instead of tested under stress
- Wind-down triggers that looked good on paper but weren't tied to real risk frameworks
These findings weren't outright refusals of authorisation, but they highlight the same question the FCA asks at the gateway: Does the plan actually work, or does it just exist?
Building an application that survives scrutiny, not just checks boxes
The throughline is that the FCA's assessment has shifted from completeness to comprehension. An application can contain every required schedule and still fail if the people behind it can't defend the substance under questioning, or if the safeguarding and wind-down arrangements haven't been rebuilt around the current rules rather than the rules that applied when a template was first drafted.
This is the gap EveryFront works to close for payments and e-money clients: not producing paperwork that looks complete, but helping firms build governance, safeguarding, and risk frameworks that the people running the business genuinely understand and can operate, so that when the FCA's questions arrive, the answers come from the firm itself.
If you built your application, or your existing wind-down and safeguarding arrangements, before PS25/12 and the FCA's September 2025 findings, the next step isn't rewriting the paperwork. It's testing whether your team can explain and operate what's already on the page.
