RAISP Application FCA: Requirements, Documents & Cost

What a RAISP Application Actually Covers

A Registered AISP (RAISP) is the FCA's entry-level registration for account information services. It allows a firm to read and aggregate payment account data — with the explicit consent of the account holder — but it does not permit payment initiation or the holding of client funds. That limited scope is precisely why the capital requirement differs from a full electronic money institution licence or an authorised payment institution: instead of a minimum cash capital, the key condition is holding adequate professional indemnity insurance.

This distinction matters in practice. Many applicants arrive with a business model that has quietly drifted into payment initiation territory, which immediately takes them out of the RAISP perimeter and into a more demanding authorisation. Identifying that boundary before submitting the file saves months of back-and-forth with the FCA.

AquaSands handles the RAISP file and the security and consent framework required by the FCA. Nothing on this page constitutes legal or tax advice; every situation must be validated case by case.

Eligibility Conditions for RAISP Registration

Before preparing any documents, the firm and its proposed activity must meet a set of conditions. Gaps here are the most common reason files stall at the FCA's gateway assessment.

• Activity strictly limited to account information services (AIS): no payment initiation, no holding of funds.
• Legal entity incorporated in the UK, or a genuine UK establishment — a registered address with no real substance or local management is a frequent ground for refusal.
• Effective management and Approved Persons who can be reached and, where required, appear before the FCA.
• Professional indemnity insurance covering AIS-related risks, sized to the projected volume of activity.
• Security policy and client consent framework meeting FCA technical standards: strong customer authentication, access management, audit logging.
• Programme of operations describing services, target markets, governance structure and business continuity arrangements.
• No disqualifying regulatory or criminal history for directors and significant shareholders.

Documents Required for the RAISP File

The FCA assesses the application on the basis of a defined set of documents. An incomplete or internally inconsistent file extends the review period and can lead to outright refusal. The core documents are:

• Certificate of incorporation and articles of association of the UK entity.
• Group structure chart and list of shareholders holding 10% or more.
• Detailed CVs and Fit and Proper declaration forms for each director and compliance officer.
• Professional indemnity insurance certificate or binding commitment from an insurer.
• Programme of operations: AIS service description, business model, target markets, three-year financial projections.
• Information security policy and client consent framework documentation.
• AML/KYC policies and procedures tailored to the target customer base.
• Business continuity plan and incident management policy.
• Identity documents and proof of address for all beneficial owners and directors.

Step-by-Step RAISP Application Process

The application follows a strict sequence. Treating steps out of order — for example, submitting the file before the insurance is in place — is one of the most avoidable causes of delay.

1. 1
   45-minute scoping call with AquaSands: eligibility check, exact activity perimeter, UK legal structure and substance assessment.
2. 2
   Firm quote and written contract: AquaSands provides a fixed price before signature; government fees are included.
3. 3
   UK company incorporation if the entity does not yet exist.
4. 4
   Drafting the programme of operations, security policies and consent framework.
5. 5
   Preparation of Fit and Proper forms for directors and significant shareholders.
6. 6
   Placement of professional indemnity insurance.
7. 7
   Submission of the complete file on the FCA's Connect portal.
8. 8
   FCA review: responding to any Requests for Information (RFI) issued by the regulator.
9. 9
   Registration granted: firm listed on the FCA public register.
10. 10
    Ongoing obligations activated: reporting, supervision, insurance maintenance.

RAISP Cost and AquaSands Fees

AquaSands publishes its fees transparently. The price includes government fees; regulatory capital (here, the professional indemnity insurance premium) and the client's own travel costs are not included. A firm quote is issued after the scoping call.

What Causes a RAISP Application to Fail

The FCA refuses or suspends the review of applications for a predictable set of reasons. Addressing these before submission is far less costly than dealing with them mid-process.

• Insufficient UK substance: a registered address with no local management or effective direction is consistently challenged.
• Professional indemnity insurance absent or under-sized relative to the declared activity volume.
• Vague or internally inconsistent programme of operations.
• Directors or shareholders failing the Fit and Proper test due to past regulatory issues, lack of relevant experience or unavailability.
• Consent and security framework not meeting FCA technical standards.
• AML/KYC procedures that are generic rather than tailored to the specific customer base.
• Permanent establishment risk: if the company is effectively managed from abroad, the FCA may question whether UK registration is appropriate — this also has tax implications that must be validated with an independent tax adviser.
• Automatic exchange of information: poorly structured arrangements can create unexpected tax obligations in the shareholders' country of residence; this is a separate validation outside the FCA process.

RAISP vs Other FCA Licences: Choosing the Right Status

Selecting the wrong status means restarting the entire application process — a significant cost in both time and fees. The decision turns on the exact scope of the proposed activity.

The RAISP is appropriate when the activity is strictly limited to reading and aggregating account data with client consent. As soon as payment initiation services (PIS) are part of the offering — even incidentally — the firm needs at minimum a Small EMI or Small PI registration. For higher-volume or uncapped operations, an Authorised Payment Institution or an Authorised Electronic Money Institution will be required.

AquaSands covers all four FCA statuses. The scoping call is specifically designed to identify the right level before any fees are committed.

Ongoing Obligations After RAISP Registration

RAISP registration does not expire: it remains valid until the FCA withdraws it or the firm surrenders it. There is therefore nothing to renew in the conventional sense, but a set of permanent obligations applies from the moment of registration.

These include maintaining adequate professional indemnity insurance at all times, meeting FCA reporting requirements, notifying the regulator of any changes to directors or significant shareholders, and continuously complying with the security and consent standards set out at registration. The annual fee published by AquaSands — €9,990 per year for the RAISP — covers the monitoring of these obligations under the service contract.

How to Start Your RAISP Application with AquaSands

AquaSands is an international structuring firm operating across 68 jurisdictions. For a RAISP FCA application, the process begins with a 45-minute scoping call, after which a firm quote and a written contract are provided before any commitment is made. Government fees are included in the price; nothing is rebilled afterwards.

Payment is accepted by bank card (in 3 interest-free instalments with Klarna for clients in the EEA, Switzerland or the UK, subject to Klarna's conditions), by bank transfer, or in USDT on the TRON network (TRC20). Every file goes through client identification and anti-money-laundering checks; AquaSands may decline an engagement.

To get started, visit the request page or go directly to the RAISP FCA licence page. For preliminary questions, the FAQ page covers the most common points, and the services overview gives a broader picture of what AquaSands delivers.