Offering finance to customers can help a business increase access, improve conversion and support larger purchases.
But in the UK, adding finance options to your customer journey can bring regulatory responsibilities. Depending on how the model works, your business may need FCA authorisation, Appointed Representative status, Introducer Appointed Representative status, approved financial promotions or another compliant route to market.
This applies to more than traditional finance firms. Retailers, platforms, publishers, lead generation businesses, service providers and customer-introduction businesses may all need to consider whether their finance journey involves regulated credit broking.
This guide explains what UK businesses should consider before offering finance to customers.
A business may think it is only helping customers access payment options. But if the business introduces customers to lenders, passes finance enquiries to another firm, promotes credit options or earns commission from finance introductions, it may be carrying out credit broking activity.
Credit broking can include:
The FCA says firms that want to engage in regulated activities as consumer credit brokers need authorisation.
For a wider overview, read What Is Credit Broking? A UK Guide to Permissions, FCA Rules and the Right Route to Market.
Before offering finance, define your role clearly.
Ask whether your business will:
The answers will shape the regulatory route.
A business that simply displays approved information may have a different position from one that actively collects customer details and routes them to lenders.
If your business introduces customers to lenders or helps them access finance, you should assess whether credit broking rules apply.
This assessment should consider the full journey, including:
The regulated activity can depend on what happens in practice, not just what the business calls it.
For a beginner-friendly explanation, read What Is Credit Broking Compliance? A Beginner’s Guide.
Once the activity is clear, consider the route to market.
Options may include:
The right route depends on the business model, customer journey, level of involvement, lender relationships, compliance resource and growth plans.
A business should not choose the cheapest or fastest route without checking whether it fits the activity.
For a detailed comparison, read FCA Authorisation Routes for Credit Brokers: Direct Authorisation, AR and IAR Status.
Direct FCA authorisation may be suitable where your business wants to hold its own permissions and control its own regulated activity.
This route may be relevant if the business:
Direct authorisation requires a clear business plan, suitable policies, financial promotion controls, complaints handling, customer journey evidence and ongoing monitoring.
For more detail, read How to Get FCA Authorisation as a Credit Broker: Step-by-Step Guide.
Appointed Representative status may be suitable where a business operates under the permissions and oversight of an authorised principal firm.
This route can work for some firms, but it still requires:
The FCA Handbook explains that the appointed representative regime is designed so clients dealing with ARs receive the same level of protection as if they had dealt with the principal firm itself.
AR status should therefore be treated as a controlled regulatory framework, not a shortcut.
Introducer Appointed Representative status is more limited than full AR status.
It may be suitable where the business only introduces customers or distributes approved financial promotions. It may not be suitable if the business is actively arranging finance, controlling the customer journey in detail or doing more than a narrow introduction.
A business considering IAR status should understand:
If the business grows beyond the original scope, the route should be reviewed.
Customers should understand what service is being offered.
A compliant customer journey should explain:
The FCA’s credit broking rules say brokers need to make clear in advertising that they are brokers and not lenders.
For a deeper explanation, read Credit Broker vs Lender: Key Differences Explained.
Offering finance usually involves customer-facing promotions.
These may include:
Promotions should be clear, fair and not misleading. CONC 3 applies to financial promotions and communications with customers, and CONC 3.7 applies specifically to credit broker promotions and communications.
Common risks include:
For practical guidance, read How to Advertise as a Credit Broker Without Breaking FCA Rules.
If your business works with lenders or finance providers, customer wording should accurately explain those relationships.
Review whether:
Lender relationship wording should match the real commercial model.
Consumer Duty is relevant where retail customers are involved.
A business offering finance should consider whether customers understand the finance journey and whether foreseeable harm is avoided.
Useful areas to review include:
The goal is to show how the business supports good customer outcomes, not just how it introduces customers to finance options.
For related guidance, read Understanding the Affordability and Suitability Rules in Credit Broking.
Offering finance often involves collecting and sharing customer information.
Review whether customers understand:
This is especially important where the business uses lead generation, affiliates, publishers or call handling.
For lead generation guidance, read Lead Generation in FCA-Compliant Credit Broking: What You Need to Know.
If finance is part of the customer journey, complaints may arise.
Customers may complain about:
A business should have a clear process for identifying, logging, investigating and responding to complaints.
Complaints should also feed into root cause analysis and customer journey improvements.
A business offering finance should keep records of compliance decisions.
Useful evidence includes:
This evidence can support FCA reviews, lender due diligence, principal oversight, platform checks and internal audits.
For audit guidance, read What to Expect During an FCA Compliance Audit as a Credit Broker.
Common mistakes include:
For more detail, read The Biggest Mistakes Businesses Make When Understanding Credit Broking.
Specialist compliance advice is useful where:
Getting the route right early can reduce delays, rework and remediation later.
Authorised Compliance helps UK businesses understand the regulatory route for offering finance to customers.
Our support can include:
We focus on practical credit broking compliance. The aim is to help firms offer finance in a way that is clear for customers, credible for partners and properly controlled.
You can read more in How Authorised Compliance Helps Credit Brokers Stay FCA-Compliant.
You may need FCA authorisation or another compliant route if your business introduces customers to lenders, passes finance enquiries, distributes credit-related promotions or earns income from finance introductions.
It can be. If your business introduces customers to lenders or helps customers access credit options, the activity may fall within credit broking depending on the model.
Yes, where a suitable authorised principal appoints the firm and the activity is within scope. The arrangement still requires oversight, approved promotions and ongoing monitoring.
An Introducer Appointed Representative has a narrower role, usually involving introductions or distributing approved financial promotions. It is more limited than full AR status.
Yes. Websites, landing pages, adverts, emails, SMS, social posts, banners and scripts that promote finance or credit broking should be reviewed before use.
Customers should understand whether the firm is acting as a broker, who the lender is, who makes the lending decision, whether commission may be received and what happens after enquiry.
Retailers may be able to offer finance, but they should assess whether FCA permissions, AR/IAR status or another compliant route is required for their model.
Yes. Authorised Compliance supports businesses with credit broking activity reviews, FCA applications, AR and IAR route assessment, financial promotion reviews, customer journey testing and ongoing compliance support.
Offering finance to customers can create commercial opportunity, but it needs the right compliance framework.
The key is to understand the real activity. If your business introduces customers to lenders, promotes credit options, passes finance enquiries or receives commission, credit broking rules may apply.
A clear route to market, accurate customer journey, controlled promotions and proper evidence can help your business offer finance in a way that is practical, compliant and built for sustainable growth.
I’m Will Hurst, and I bring 20+ years of hands-on experience across credit broking, AR/IAR oversight, lender relationships and regulated finance operations.
Learn more about my practical, FCA-focused approach
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