The purpose of this page is to make sure that the application process for Company Managers is fully understood.
This section sets out:
- What a Company Manager is and what this regulated activity would allow you to do
- Authorisation process
- Capital Requirements
- Additional Information
What is a Company Manager and what would this regulated activity allow you to do?
A Company Manager provides company or corporate administration by way of business. A Company Manager permission allows a firm to carry out a range of activities, which includes, but is not limited to:
- the formation, management or administration of companies, partnerships or other unincorporated bodies
- provision of corporate or individual directorship services
- provision of corporate or individual secretary or in any other capacity as officer of a company, partnership or other unincorporated body other than a director
- provision of nominee services, including (without limitation) acting as or providing nominee shareholders; and
- provision of Registered Office facilities.
Individuals applying for permission to provide directorship services in an individual capacity are only required to submit an Application form.
Individuals seeking authorisation are required to be associated to and provide services to an already regulated Company Manager.
Following successful completion of the pre-application process, applicants should submit an application in line with the Staged Application for Authorisation Approach.
Initially, the applicant will only submit the Stage 1 application information - it is important that only Stage 1 information is provided at the outset of the application process.
The GFSC will communicate to the applicant that the application can progress to the next stage once the GFSC is satisfied with the content provided at the current stage. The applicant will then be invited to submit the further information required at the next stage of the application process.
Please request cloud access from the GFSC to submit the information requested, via e-mail to [email protected], stating in the subject field: ‘Name of Applicant – Application’. Paper copies are not required unless indicated by the team.
Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.
Stage 1 - Business Model, Capital & Key Individuals
The following is to be submitted for Stage 1:
On receipt of the application fee and Stage 1 documents, the GFSC will confirm the GFSC Supervisor who has been assigned to assess the application for authorisation.
Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 1 will be communicated to the applicant during Stage 1.
When the GFSC is satisfied with all the responses and information/documentation received, the GFSC will inform the applicant that its application can progress to Stage 2.
Stage 2 - Risk Management, IT Systems, Corporate Governance & Financial Crime
The following is to be submitted for Stage 2:
- Stage 2 of the General Comprehensive Business Plan (not including Stage 3);
- Documentation and information including, but not limited to:
- Corporate Governance and control
- Business Continuity Management Plan
- IT infrastructure, Cyber and systems including outsourcing arrangements
- Operational & Outsourcing Risk including material outsourcing arrangements
- Systems controls & Risk Management
- Financial Crime controls, compliance with Anti-Money Laundering/Combating the Financing of Terrorism requirements (as applicable)
- Risk Methodology and framework policy documents
- Risk Register & controls
- Disaster Recovery Plan
- Updated business plan, if required.
Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 2 will be communicated to the applicant during Stage 2.
When the GFSC is satisfied with all the responses and information/documentation received from an applicant, the GFSC will inform the applicant that its application can progress to Stage 3.
Stage 3 - Conduct of Business, Non-Financial Resource, Policies & Procedures
The following is to be submitted for Stage 3:
- Stage 3 of the General Comprehensive Business Plan;
- Documentation and information including, but not limited to:
- Non-financial resources
- Compliance structure
- Conduct of Business (Full Conduct Risk Framework documents)
- Detail of KPIs
- Consumer Duty compliance (as applicable)
- Operational Resilience compliance (as applicable)
- Remuneration Policy
- Conflict of Interest Policy
- Conflict of Interest Register
- Liquidity/solvency policies
- Internal Audit Plan
- Complaints Handling Policy
- Terms of Reference of the Board, Board sub-committees, Risk Committee and/or Audit Committee, Underwriting/Pricing committees, as applicable
- Audit, accounting, and banking arrangements
- Professional Indemnity Insurance
- Contracts with parties to whom material operational functions are outsourced
- Completed and signed Regulated Individual Forms and Non-Executive Director Forms
- Mobilisation Plan (if applicable).
When the GFSC is satisfied with the Stage 3 responses and information, the application will move to a GFSC decision for authorisation.
Only one regulated firm within a group must be capitalised at the minimum regulatory requirement.
An applicant shall, unless previously agreed in writing by the GFSC, have a paid-up share capital of substance depending on its business that shall not be less than £10,000.
In addition to the above capital requirement, an applicant is expected to maintain a minimum level of financial resources equivalent to three months’ worth of operating expenses (or as projected at application) and the measure of these financial resources shall be the net asset figure in the applicant’s balance sheet.
Before being authorised to carry out the proposed activity, firms holding multiple authorisations may be required to hold the aggregate of the capital necessary for each authorisation, including on an ongoing basis. In these cases, we will consider the level of capital on a case-by-case basis. Applicants are encouraged to discuss this with the GFSC ahead of their application.