Do I need to be VAT registered to apply for FCA authorisation?

No. VAT registration is not a requirement when applying for authorisation from the Financial Conduct Authority. Many new businesses and startups apply while operating below the VAT threshold, and not having a VAT number will not affect an FCA application.

VAT does become relevant in two other situations, which is where the confusion usually comes from.

When VAT becomes relevant

Crossing the threshold

If you expect the business to generate significant revenue after authorisation, you may reach the VAT registration threshold - currently £90,000 of taxable turnover in a twelve-month period, per HMRC guidance (opens gov.uk in a new tab). VAT is not required at the point of applying for FCA authorisation, but if you cross the threshold during the process you will need to register to stay compliant with HMRC rules.

Threshold correct as at August 2026. VAT thresholds are reviewed periodically - check the current figure before relying on it.

Working with lenders and brokers

The second situation is commercial rather than regulatory. Lenders and brokers generally require VAT registration before they will work with a firm, often as an onboarding condition intended to confirm they are dealing with established businesses.

This is a lender’s requirement, not the FCA’s. It is worth establishing early, because a firm that secures authorisation and then discovers its intended lending partners will not onboard it has solved the wrong problem first.

In summary

You do not need to be VAT registered for FCA authorisation. Other circumstances may require it anyway.