How to obtain a DBS check for the principal

To register as a principal with the Financial Conduct Authority (FCA), you must obtain a Disclosure and Barring Service (DBS) check to prove you are "fit and proper" to run a financial business. You should apply for this before you submit your Senior Management Function (SMF) application, as you will need the certificate number or the application reference to complete your regulatory forms.

Determine the level of check required

The type of DBS check you need depends on your specific role and the nature of your business. While a Basic check shows unspent convictions, the FCA usually requires a Standard check for individuals performing Senior Management Functions. A Standard check is more thorough, showing both spent and unspent convictions, cautions, reprimands, and final warnings.

How to apply

The application process differs depending on the level of disclosure you are seeking:

• Basic Check: You can apply for this yourself directly through the GOV.UK website. It costs £18 and typically takes up to 14 days.
• Standard Check: You cannot apply for a Standard check as an individual. You must apply through a "registered body" (often called an umbrella company) or via the FCA's own preferred supplier if they have directed you to one within the Connect portal.

The application process

1. Gather your ID: You will need original documents to prove your identity, such as a valid passport, driving licence, and recent utility bills or bank statements (usually dated within the last three months).
2. Complete the form: Whether online or on paper, ensure your five-year address history is accurate and has no gaps. Any inconsistencies can lead to significant delays.
3. Identity Verification: If applying through an umbrella body, you may need to have your documents verified at a Post Office or by a professional (like an accountant or solicitor).
4. Receive your certificate: The DBS will post a hard-copy certificate to your home address.

Top Tip: Apply for your DBS check as early as possible. It is often the primary reason for delays in the FCA authorisation process. The FCA will not usually progress your application until they have the results of this check.

What to do when the certificate arrives

Once you receive your certificate, check it for any errors. You will need to input the 12-digit certificate number and the date of issue into your FCA SMF application. Keep the original paper certificate in a safe place, as the FCA may request to see the physical copy during their assessment.

Check Type	What it shows	Who can apply?
Basic	Unspent convictions	Anyone
Standard	Spent and unspent convictions, cautions	Via a registered body only

Remember that a DBS check is a "point in time" document. If there is a long delay between receiving your certificate and submitting your FCA application, the regulator may ask you to perform a fresh check if the current one is more than 90 days old.