The UK's Financial Conduct Authority has published a guide to help firms apply for 'permissions' to conduct business in accordance with the European Union's Markets in Financial Instruments Directive.

Every firm that has to change its regulatory 'permissions' as a result of MiFID II is invited to submit a complete application for authorisation or a variation of permission as soon as possible. The FCA appears to be nervous about its ability to process applications in time. It writes: "To be sure that we can determine an application in time for 3rd January 2018, it needs to be complete by 3rd July 2017. Most applications are not complete when they are submitted."

The FCA is taking this opportunity to warn firms that any authorised firm that undertakes regulated activities without the FCA's permission to do so will contravene s20 Financial Services and Markets Act. The FCA might then punish it with the following.

• Disciplinary sanctions including public censure, financial penalties or the suspension or restriction of their permissions under Part 14 FSMA.
• The FCA's OIREQ (Own Initiative Requirement) and OIVOP (Own Initiative Variation of Permission) powers under Part 4A.
• Powers of injunction and restitution under Part XXV FSMA.
• The invocation of rule SYSC 6.1.1R in relation to systems and controls.