The published service standard is the least useful figure in the process. A supervisor that says it will assess a complete application within six months is telling you what happens after the file is accepted as complete, and completeness is the hard part. Applications commonly sit in a pre-submission state for a quarter or more while the applicant assembles what was asked for on day one.
What follows is the shape the process takes across the main licensing regimes. Names and thresholds differ between the FCA, CySEC, ASIC, the DFSA and the offshore authorities, but the sequence is remarkably consistent.
Phase one: structure and jurisdiction, four to eight weeks
Before a single form is filled, three decisions get made and each one constrains everything after it. Which activities you want permission for, because a licence to receive and transmit orders is a different application from one that lets you deal on own account. Which jurisdiction, which sets capital, reporting and passporting. And who the shareholders and directors will be, because those people are the ones the regulator assesses.
The choice of regime is where founders lose the most money by choosing badly, and the trade-offs are laid out in our comparison of licence costs and in FCA versus CySEC. Take the decision on where your clients are and what your distribution needs, not on the headline fee. An offshore licence obtained in eight weeks is worthless if your payment providers will not underwrite it.
Phase two: assembling the pack, eight to sixteen weeks
This is the phase that determines the total. The file typically contains a three year business plan with financial projections that survive being questioned, a regulatory business plan describing the model in operational detail, the full compliance manual, the AML and counter-terrorist financing policy with a named MLRO, risk management framework, outsourcing register, business continuity plan, complaints procedure, client categorisation policy, conflicts of interest policy, and the organisational chart with reporting lines.
Alongside those sit the personal files for every director, shareholder above the notification threshold and key function holder: CVs, references, criminal record certificates, sworn declarations, and source of wealth evidence. That last item causes more delay than any other single document. A shareholder who cannot document how he came by his money, with bank statements and transaction records rather than an assertion, will stall the application indefinitely.
Two practical points. Regulators read business plans and compare them against the permissions requested, so a plan describing a book you will hedge internally while applying for a permission set that does not allow it gets returned. And the technology section is examined: you will be asked which platform you will operate, which liquidity providers you will use, how client data is protected, and how records are retained. Vague answers there produce a round of questions that costs a month.
Phase three: submission and the review rounds, three to nine months
Submission does not start the assessment clock. The supervisor first checks the file is complete, and an incomplete file goes back with a list. When the application is accepted, a case officer is assigned and the substantive review begins.
Review happens in rounds. The officer sends written questions, you respond, another set follows. Three to five rounds is normal. The questions get progressively narrower: broad model questions first, then specifics on capital adequacy calculations, then on the compliance monitoring programme, then on individual clauses in the client agreement. Response time is yours to control and it is where applicants lose weeks. A question answered in four days keeps momentum. The same question answered in three weeks, because it went to a lawyer who went on holiday, is three weeks added to the total.
Nominate one person to own the response file with authority to sign off answers. Applications that route every question through a committee of shareholders take roughly twice as long as those that do not.
Fit and proper assessment runs in parallel. Directors are interviewed in several regimes, and the interview is technical: expect to be asked how your own risk limits work, how a specific complaint would be handled, and what you would do if a client disputed an execution price. Reading the answers off a compliance manual you did not write is visible immediately.
Phase four: capital, banking and conditional approval, four to twelve weeks
Most regimes issue an approval in principle before the licence itself. The conditions typically require the initial regulatory capital to be deposited in a bank account in the applicant's name, the client money accounts to be opened and evidenced, key staff to be in post rather than merely named, and the operational infrastructure to be demonstrably live.
Opening the bank accounts is the step that surprises people. A newly incorporated financial firm with an approval in principle and no trading history is a difficult account for a bank to open, and eight to twelve weeks is common. Start the conversations during phase two, not after the conditional approval arrives, and expect to be asked for the same documents you gave the regulator. The banking side of this is covered in banking for trading firms.
Client fund arrangements must satisfy the segregation rules in your regime, which means named trust accounts with acknowledgement letters from the bank, not simply a second account in the company name.
Phase five: licence issued, and the work that starts
The licence arrives with conditions and reporting obligations that begin at once. Regulatory returns on a set cycle, capital adequacy monitoring, transaction reporting where MiFIR or an equivalent applies, an annual compliance report, an external audit, and in most regimes a notification duty for any change of control, director or material outsourcing.
Firms that treated the compliance manual as a document written to obtain a licence discover the gap in the first supervisory review, because the manual describes controls that must actually run. That is where operational tooling stops being a nice-to-have: audit trails, client categorisation held as data rather than in a spreadsheet, and evidence that KYC refreshes happened on schedule. Our Broker CRM exists to hold that record, though the licensing and compliance obligations themselves remain the operating firm's entirely.
A realistic total
For a mainstream European or Australian regime with a prepared applicant and responsive advisers, twelve to eighteen months from first decision to first client is a fair planning assumption. Offshore regimes compress the middle phases substantially and the pre-application work barely at all. Anyone quoting you a fixed number without having seen your shareholder structure is guessing, and the honest answer is that your own responsiveness is the largest variable in it.
"Almost nobody is delayed by the regulator. They are delayed by their own document pack, by a director who cannot evidence his source of wealth, and by a bank that takes eleven weeks to open the capital account."
— Roman Onta, Executive Director, SINGUARD
Key Takeaways
- The regulator's published assessment period starts only once your file is accepted as complete, which is usually months after you first submit.
- Source of wealth evidence for shareholders is the single most common cause of an application stalling.
- Reviews run in written question rounds, and your own response speed is the biggest controllable factor in the total duration.
- Approval in principle is conditional on depositing regulatory capital and opening segregated client accounts, and bank onboarding alone often takes eight to twelve weeks.
Frequently Asked Questions
How long does a broker licence application take?
For a mainstream regime, twelve to eighteen months from the first structural decision to onboarding a client is a realistic plan. The regulator's own assessment window is a subset of that; document preparation, question rounds and bank account opening account for most of the elapsed time.
What delays a licence application most often?
Incomplete document packs, shareholders who cannot evidence their source of wealth, and slow responses to the regulator's written questions. Bank account opening after conditional approval is the other common bottleneck.
What happens after the licence is granted?
Reporting obligations begin immediately: periodic regulatory returns, capital adequacy monitoring, transaction reporting where it applies, an annual compliance report and an external audit. Changes of control, directors or material outsourcing arrangements normally require notification or prior approval.
About the Author
Roman Onta is an Executive Director at SINGUARD. He builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals side by side with his brother Alex Onta, and he helped on the design of eTrader, the division Alex built and leads. His ground is worldwide payment processing, AML compliance and the corporate structures brokers are built on, work the two of them carry together, shaped by executive roles in the UAE and international corporates. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.