Form FCL504 Issue 7 (SRG1102)
It is an offence to make, with intent to deceive, any false representations for the purpose of procuring the grant, issue, renewal or variation of any certificate, licence, approval, permission or other document. Persons doing so render themselves liable, on summary conviction, to a fine not exceeding the statutory maximum (currently £5000, or in Northern Ireland £2000) and on conviction on indictment to an unlimited fine or imprisonment for a term not exceeding two years or both. A Cancellation Charge may be applied as per the CAA scheme of charges when an active application request has been cancelled by the CAA or the customer.
The important bit here is "with intent to deceive" in the first line. I think that will be hard to prove.