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Variations of permissions

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Variation of Permission for Payment or Electronic Money Institution

If your payment services firm plans to introduce new regulated activities, discontinue existing services, or modify existing regulatory requirements (such as capital thresholds), you’ll need to submit a Variation of Permission (VoP) application to the FCA.

However, VoP applications cannot be used to change your firm’s status—for example, you cannot use this process to switch from:

Authorised to registered status
Authorised to small payment institution
Account Information Service Provider (AISP) to Payment Institution (PI)
Payment Institution to Electronic Money Institution (EMI)

The Permissions for Payment Services

Here’s a breakdown of the permissions available under the Payment Services Regulations:

  1. Enabling cash deposits into a payment account and all related operations

  2. Enabling cash withdrawals from a payment account and related operations

  3. Executing payment transactions (funds on a payment account):

a. Direct debits (including one-off)
b. Transactions via payment cards or similar devices
c. Credit transfers, including standing orders

  1. Enabling cash deposits into a payment account and all related operations

  2. Enabling cash withdrawals from a payment account and related operations

  3. Executing payment transactions (funds on a payment account):

    a. Direct debits (including one-off) b. Transactions via payment cards or similar devices c. Credit transfers, including standing orders

  4. Executing transactions with credit lines:

    a. Direct debits (including one-off) b. Payment card transactions c. Credit transfers, including standing orders

  5. Issuing payment instruments and acquiring payment transactions

  6. Money remittance (sending money without holding a payment account)

  7. Payment initiation services (PISP)

  8. Account information services (AISP)

  9. Issuing electronic money

Common Applications

Permissions 1–4 allow firms to offer and operate payment accounts. Note: payment institutions must receive a payment order before accepting or holding client funds.
Permission 5 enables issuing of card-based payment instruments.
Permission 6 supports money remittance without needing a customer account.
Permissions 7 and 8 apply to PISPs and AISPs—respectively enabling direct merchant payments and the aggregation of account data for customers.
Permission 9 applies only to e-money firms. These firms can hold balances (e-wallets) without needing a payment order, much like a bank, but without paying or earning interest.

What Do I Need to Provide With the Application?

The requirements are similar to those of your original licence application, though tailored to the specific permission(s) requested. Typically, you’ll need to submit:

A detailed business plan explaining how the variation fits into your overall strategy
Organisation charts showing the individuals responsible for the new regulated activities
An explanation of how the firm will meet regulatory obligations for both current and proposed services
Risk and compliance controls related to the new activities

How PayWise Compliance Can Help With Your Variation of Permission

If you’re looking to expand, adjust, or redefine the services your firm offers, PayWise Compliance can guide you through:

Identifying the correct permissions and associated requirements
Ensuring your business is fully prepared to meet FCA standards
Planning, drafting, and submitting your VoP application accurately and efficiently

Let us help ensure a smooth and successful variation process for your regulated firm.

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About Us

We are a UK-based compliance consultancy dedicated to supporting financial services firms in meeting their regulatory obligations with confidence and clarity. Operating exclusively within the UK regulatory framework, we assist businesses at every stage of their journey—whether navigating the complexities of authorisation or maintaining ongoing compliance.

Our strength lies in the depth of expertise across our team. With a combined foundation of over 25 years’ experience in financial services, we bring practical insight, regulatory understanding, and strategic guidance to every engagement. We do not offer generic solutions; instead, we deliver tailored advice that reflects the realities of your business and the expectations of the regulator.

We understand that today’s regulatory landscape is demanding, fast-moving, and often challenging. That is why we position ourselves not simply as advisers, but as your long-term compliance partner. From initial application through to day-to-day oversight, we work alongside you to make complex processes clear, manageable, and efficient.

Our focus is on achieving the right outcome—every time. By combining technical excellence with a client-centred approach, we help firms progress with confidence, minimise regulatory risk, and build sustainable, compliant operations. With us, compliance becomes not a barrier to growth, but a foundation for it.

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