Pre-application meeting: documents to prepare
Short answer
Before a pre-application meeting, prepare a business plan, a governance and staffing overview, draft policies on safeguarding client assets and handling complaints, and a short outline of your IT and security setup. The supervisor uses these papers to scope the meeting, not to approve anything at this stage. Bring drafts rather than final versions — the meeting exists to catch gaps early, while changes are still cheap.
What changes once the meeting is booked
Booking the meeting starts an informal clock, even though no statutory deadline runs yet. The officer assigned to your file forms a first impression from the papers you send in advance, and that impression carries into the formal review later. Gaps raised now are usually fixed with a short follow-up email. The same gaps raised after the formal file is opened tend to trigger a written deficiency letter and a pause in the review.
This is the point where preparation pays off most. A thin business plan or a missing safeguarding policy rarely stops a meeting from happening, but it does shape how much scrutiny the file receives afterwards.
What to prepare, step by step
- The founder or managing director drafts a business plan covering the activity, target clients, and revenue model in plain terms.
- The compliance officer prepares a governance chart showing reporting lines, key function holders, and decision-making authority.
- The compliance officer drafts internal policies on safeguarding client funds or assets, conflicts of interest, and complaint handling.
- The technical lead prepares a short written summary of the IT architecture, custody arrangement, and incident-response approach.
- The board or equivalent body reviews and signs off on the drafts before they go to the supervisor.
- The compliance officer sends the pack to the supervisor's authorisation team with a short cover note listing open questions.
Documents to bring
| Document | Purpose at this stage | Who prepares it |
|---|---|---|
| Business plan | Gives the officer the activity and business model before the meeting | Founder or managing director |
| Governance overview | Shows who holds which decision and who is accountable | Compliance officer |
| Draft safeguarding policy | Signals how client funds or assets stay protected | Compliance officer |
| Draft complaints policy | Shows how client disputes are logged and resolved | Compliance officer |
| IT and security summary | Outlines custody, access control, and incident response | Technical lead |
| Open-questions note | Tells the officer where you expect feedback | Whoever leads the file |
Who decides and how long it takes
The meeting is arranged directly with the authorisation team inside the national supervisor. There is no fixed statutory waiting period for the meeting itself, and the exact timing depends on the supervisor's current caseload. A written follow-up from the supervisor after the meeting is common but not guaranteed, so it helps to ask directly whether one will be sent.
Nothing decided at this stage is binding. The meeting narrows the scope of the formal file; it does not open or close it.
If your situation differs
- If your business model spans several regulated activities, split the business plan into separate sections per activity so the officer can scope each one on its own.
- If your capital structure is still being finalised, say so directly in the cover note rather than presenting draft numbers as final.
- If you already hold an authorisation elsewhere in the EU, bring a short comparison note showing which parts of your setup carry over unchanged.
What this page does not cover
This page does not cover the technical assembly and formal submission of the file that follows the meeting; that stage has its own document checklist and timing — see File assembly and submission step by step.
It does not cover remediation steps after a supervisory finding once a licence is already active — see Remediation after a finding step by step.
It does not cover disputes over trade marks or designs that sometimes surface during due diligence on a brand — see Interim relief in brand disputes step by step.
It does not cover ownership disputes over code raised by a contractor during technical review — see Games and interactive entertainment — when a contractor claims.
Verified
This page reflects standard administrative practice around pre-application meetings with a national supervisor. Procedures and expected documents vary between supervisors and are reviewed periodically as practice evolves. Confirm current expectations directly with the assigned officer before the meeting.
Related publications
For the stage that follows this meeting, see File assembly and submission step by step.
Next steps
If your licence question involves a token that keeps operating after the underlying agreement has ended, see When a licence terminates but the token remains.
If your offer already targets several countries at once, see When the offer targets several countries.
FAQ
How long does a pre-application meeting take in practice?
Most meetings run under two hours. The exact length depends on how many open questions the cover note raises and how detailed the draft policies already are.
Which documents are needed to start?
A business plan, a governance overview, and draft safeguarding and complaints policies are enough to schedule the meeting. Everything else can follow as a draft.
What happens if the supervisor does not respond after the meeting?
A written follow-up is common but not owed. If nothing arrives within a reasonable period, a short written request for confirmation of next steps is the usual way forward.