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Financial Conduct Authority

United Kingdom custody/client assets licensing requirements

Safekeeping, client money, custody control, qualified custodian, safeguarding, asset segregation, and client asset operational models. This page maps the issue to United Kingdom application evidence, individual roles, corporate controls, public registers, and official sources.

Who this page is for

  • - Custodians
  • - Managers with custody risk
  • - Platforms handling client money
  • - Brokers and fund operators
  • - Discretionary investment managers
  • - Wealth and stockbroking firms

Likely route questions

  • - FCA safeguarding, custody, CASS, arranging custody, and prudential analysis

Activity trigger map

  • - Can the firm move, instruct, deduct from, or otherwise control client assets?
  • - Are client assets held directly, by a custodian, by a fund vehicle, or through a platform?
  • - What audit, segregation, disclosure, capital, and reporting controls are needed?
  • - Which entity will hold, safeguard, control, or arrange custody of client assets?
  • - How will professional, accredited, institutional, or wholesale client status be evidenced and monitored?
  • - Which domestic permissions, representative approvals, and ongoing obligations apply before launch?

Individual requirements

  • - Senior Manager Function approval where a controlled function applies
  • - Certification for relevant staff under SM&CR where applicable
  • - Conduct Rules training and fit and proper assessment
  • - Clear allocation of responsibility for compliance, money laundering reporting, and operations

Corporate requirements

  • - UK entity or branch model with permissions, investment types, and client types mapped
  • - Regulatory business plan, financial forecasts, capital/prudential analysis, and systems and controls
  • - SM&CR mapping, governance, compliance monitoring, AML, complaints, CASS, outsourcing, and wind-down planning
  • - Evidence that the firm is ready, willing, and organised at application stage

People and key-person expectations

  • - Senior Manager Function approval where a controlled function applies
  • - Certification for relevant staff under SM&CR where applicable
  • - Conduct Rules training and fit and proper assessment
  • - Named owners should be able to explain the activity workflow, client type, controls, and evidence pack.

Documents and evidence checklist

  • - Custody and client assets
  • - Capital and financial resources
  • - Compliance framework
  • - Outsourcing and vendors
  • - Regulatory reporting
  • - Official-source route memo
  • - Public register verification plan
  • - Questions log for qualified advisers

Capital, timeline and bottlenecks

Capital and prudential requirements depend on the permissions, MiFID/MIFIDPRU status, client asset position, and business model.

Timeline estimate: FCA service standards distinguish complete and incomplete applications; practical timelines often run 4 to 10+ months.

  • - Permissions requested do not match the actual operating model
  • - Financial forecasts are inconsistent with the applicant legal entity or prudential category
  • - Weak governance, SM&CR ownership, or compliance monitoring
  • - CASS, outsourcing, wind-down, and technology controls are not tailored to the firm

Common mistakes

  • - Saying the firm does not hold assets while retaining practical control over movements.
  • - Not documenting qualified custodian, CASS, client money, or safeguarding assumptions.
  • - A consultant can help, but the FCA still expects the firm to understand and own its application.
  • - SM&CR is not just an HR exercise; it shapes accountability evidence.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.