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UK Banking License in 2026: PRA/FCA and the Mobilisation Route

A 2026 deep dive into the UK banking licence: PRA and FCA dual authorisation, the mobilisation route with GBP 50,000 deposit cap and 12-month window, GBP 55,740 application fee, realistic capital and the reference challenger-bank path (Monzo, Starling, Atom).

UK Banking License in 2026: PRA/FCA and the Mobilisation Route
UK Banking License in 2026: PRA/FCA and the Mobilisation Route
UK Banking License in 2026: PRA/FCA and the Mobilisation Route

The UK banking regime and the two supervisors

A UK banking licence is issued under the Financial Services and Markets Act 2000 (FSMA). Two regulators share the authorisation:

  • Prudential Regulation Authority (PRA). Part of the Bank of England. Prudential supervisor: capital, liquidity, recovery and resolution. Takes the final authorisation decision.
  • Financial Conduct Authority (FCA). Conduct supervisor: consumer protection, market integrity, competition.

The New Bank Start-up Unit (NBSU) is a joint PRA-FCA team that supports new bank applicants through authorisation. Most UK challenger banks (Monzo, Starling, Atom, Tandem, Zopa, Oaknorth, Metro, Monese, Kroo, Allica) went through the NBSU.

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The mobilisation route: UK's secret weapon

The UK is the only major jurisdiction that offers a formal mobilisation route. Mobilisation is an optional stage in which a new bank is authorised with restrictions and can complete the final build-out while already holding a full bank licence.

During mobilisation

  • Full UK banking licence granted
  • Deposit-taking permission restricted to GBP 50,000 total during the window
  • Up to 12 months to complete build
  • Secure further investment, hire staff, sign supplier contracts
  • Proportionate PRA/FCA oversight

Exit mobilisation

  • PRA/FCA assess operational readiness
  • Systems, staff, capital in final form
  • Deposit cap removed
  • Bank becomes fully operational
  • Commercial launch begins

Mobilisation is the single biggest structural reason UK banking is easier to enter than any EU jurisdiction. Firms that know they will need 12 to 18 months of final-stage operational build after capital is raised pick the UK specifically for this route.


Capital, fees and realistic numbers

  • Application fee. GBP 55,740 total (covers both PRA and FCA fees). Paid once at submission.
  • Initial capital. EUR 5 million equivalent (PRA uses the same CRR floor). In practice, credible new banks launch with GBP 20M to GBP 100M of CET1.
  • Ongoing capital. CRR Pillar 1 (8% total capital, 4.5% CET1, 6% Tier 1) plus buffers plus PRA Pillar 2.
  • Mobilisation deposit cap. GBP 50,000 total (not per customer) during the mobilisation period.
  • Supervisory fees. Scale by size; GBP 150k to GBP 500k+ per year depending on class.

Authorisation process and timeline

  1. NBSU pre-application (6 to 12 months). Multiple meetings with the PRA and FCA. Business model, capital plan, governance framework.
  2. File build (6 to 9 months). Full authorisation file (typically 1,500 to 3,000 pages). Business plan, Recovery and Resolution Plan, ICAAP, ILAAP, risk framework, operational resilience, governance, AML, systems architecture, fit-and-proper SMCR files.
  3. Submission. Via FCA Connect and PRA channels.
  4. Assessment (6 to 12 months). PRA-led with FCA input.
  5. Authorisation with restrictions (mobilisation) granted.
  6. Mobilisation period (up to 12 months). Build out final systems, hire, contract.
  7. Exit mobilisation. PRA/FCA sign off on readiness. Full trading begins.

Total end-to-end: 18 to 30 months from serious planning to full commercial launch. Faster than any EU jurisdiction other than Lithuania's specialised bank.


Substance, SMCR and Consumer Duty

  • SMCR. Senior Managers and Certification Regime with individual accountability for prescribed functions.
  • UK substance. UK head office, UK-resident CEO, CFO, CRO, CCO, Head of Internal Audit.
  • Board. Independent Chair, balanced executive/non-executive mix, Audit and Risk Committees.
  • Consumer Duty. In force since 31 July 2023. Retail-facing banks deliver good outcomes across products, price, understanding and support.
  • Operational resilience. PS21/3 impact-tolerance regime fully embedded.
  • APP fraud. Mandatory reimbursement scheme from 7 October 2024 for Faster Payments and CHAPS.

Supervision and reporting

  • Supervisory team. PRA and FCA dedicated relationship managers proportionate to size. Larger banks assigned PRA category 1-3 supervisory intensity.
  • ICAAP and ILAAP. Annual internal capital and liquidity assessment.
  • Recovery and resolution. Annual recovery plan; resolution plan co-owned with the Bank of England.
  • Regulatory returns. COREP and FINREP (UK-variant), FSA-specific returns, depositor compensation scheme data, FINREP-UK.
  • Ring-fencing. Banks with retail deposits above GBP 25 billion must ring-fence retail banking from investment banking (does not apply to challenger banks under the threshold).

Ship a UK bank product with Crassula

Crassula delivers the composable core banking platform: ledger, deposits, lending, cards, Faster Payments, Bacs, CHAPS, SEPA, KYC and AML, treasury, IFRS 9 ECL, Consumer Duty MI, operational resilience mapping and PRA/FCA-ready reporting. The same platform supports small and challenger banks through to full-scope UK bank operations.


FAQ

Jointly the PRA and FCA. The PRA takes the final decision; the FCA supervises conduct. The joint New Bank Start-up Unit (NBSU) supports new applicants through authorisation.

An optional stage in which a new bank is authorised with deposit-taking restricted to GBP 50,000 total for up to 12 months. The bank holds a full licence while building out systems, staff and supplier contracts. Most UK challenger banks used the route.

EUR 5 million equivalent initial capital (PRA uses the CRR floor). In practice, credible new banks launch with GBP 20 million to GBP 100 million CET1 plus a multi-year funding plan.

GBP 55,740 total for a new bank, covering both PRA and FCA fees.

18 to 30 months from serious planning to full commercial launch. Faster than any EU jurisdiction other than Lithuania's specialised bank.

Crassula provides the composable core: ledger, deposits, lending, cards, Faster Payments/Bacs/CHAPS/SEPA, KYC/AML, treasury, IFRS 9, Consumer Duty MI and PRA/FCA-ready reporting.

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