Category: Compliance & AML · Reviewed by Amy Price, Account Executive · Last reviewed June 2026
The statutory mechanism by which an authorised firm changes the scope of its Part 4A Permission — adding, removing or restricting regulated activities, customer types or investment instruments.
A Variation of Permission (VOP) is the formal application a firm makes when its Part 4A Permission needs to change. A VOP can be initiated by the firm itself (an “own initiative” VOP application, abbreviated OIVOP — though that label is more commonly used when the FCA initiates it under section 55J) or by the FCA (an OIREQ — Own Initiative Requirement — or a section 55J variation).
FSMA sections 55H (variation on the application of the authorised person), 55I (cancellation on the application of the authorised person) and 55J (variation or cancellation on the initiative of a regulator). FCA Handbook, SUP 6.
A firm-initiated VOP is filed via Connect using the VOP application. The FCA processes the application against the Threshold Conditions and the firm’s evidence of capability for the new activity. Common reasons for a VOP include adding a new permission (e.g. credit broking to support premium finance), removing a redundant permission, broadening customer types, or accepting a requirement to address a perceived issue. The FCA can also impose a VOP under section 55J on its own initiative — for example, restricting a firm’s activities pending remediation.
Where speed is needed, the FCA can use Own Initiative Requirement (OIREQ) powers under FSMA section 55L (FCA) to impose a requirement without changing the permission itself — for example, a customer-asset restriction, a marketing freeze, or an attestation. These are often the precursor to enforcement.
A general insurance broker wanting to start offering loans for premium finance would apply for a VOP to add the regulated activity of credit broking (article 36A RAO). A broker exiting commercial lines might apply to remove the relevant customer-type permission.
Financial Services and Markets Act 2000, sections 55H, 55I, 55J, 55L. FCA Handbook, SUP 6.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
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