Credit broking compliance is easier to manage when the business has a clear checklist and a practical framework.
For UK credit brokers, compliance affects the full operating model. It is not limited to FCA authorisation or policy documents. It includes the way the business generates leads, describes its role, works with lenders, reviews financial promotions, explains commission, handles complaints, monitors outcomes and keeps records.
This checklist is designed to help credit brokers review the main areas that should be controlled before launch and monitored as the business grows.
It is not a substitute for tailored advice, but it can help firms identify where their current framework may need attention.
Start by confirming whether the business is carrying out regulated credit broking activity.
You may need to consider whether the firm is:
Once the activity is clear, assess the right regulatory route.
This may include:
A firm should not assume it is outside the FCA perimeter simply because it is not the lender.
For further reading, see What Is Credit Broking Compliance? A Beginner’s Guide, Why FCA Authorisation Matters for Credit Brokers and How to Get FCA Authorisation as a Credit Broker: Step-by-Step Guide.
If your firm is directly authorised, check that your permissions match the activity you actually carry out.
If you operate as an Appointed Representative or Introducer Appointed Representative, check that your activity is within the agreed scope.
Review whether the business has changed since the permissions or appointment were agreed. For example:
AR and IAR status should not be treated as a shortcut. These are regulated relationships that require clear responsibilities, oversight, monitoring and evidence.
For more on routes to market, read Advanced Strategies for Mastering What Are the Two Types of FCA Authorisation for Firms.
Customers should understand whether they are dealing with a broker or a lender.
A credit broker should make its role clear across:
It is not enough to mention broker status in a footer if the main customer journey gives a different impression.
Check whether customers can clearly understand:
For more detail, read Credit Broker vs Lender: Key Differences Explained.
Financial promotions are one of the most important compliance areas for credit brokers.
Review all promotional material, including:
Ask whether each promotion is:
Avoid claims that are difficult to evidence. For example, do not use “whole of market” unless that can be supported by the actual lender relationship model.
For a detailed guide, read How to Advertise as a Credit Broker Without Breaking FCA Rules.
Reviewing promotions is only useful if the firm can evidence what was approved.
Keep records of:
A firm should be able to show that financial promotions are controlled before and after publication.
This evidence can be important during FCA reviews, principal reviews, lender due diligence or internal audits.
A customer journey review helps identify where customers may be confused or unsupported.
Map the full journey from first advert to outcome.
This may include:
The journey should be clear, consistent and aligned with the firm’s regulatory status.
For lead generation models, read Lead Generation in FCA-Compliant Credit Broking: What You Need to Know.
Credit brokers often work with lenders, finance providers or selected panels.
Review whether your customer communications explain those relationships accurately.
Consider:
The aim is to help customers understand how the broker relationship works and whether commercial arrangements may be relevant to the service they receive.
Consumer Duty should be built into the compliance framework.
Credit brokers should consider whether customers receive information they can understand, whether the service meets the needs of the target market and whether customer outcomes are monitored.
Useful evidence may include:
The key question is not only whether the firm has a Consumer Duty policy. It is whether the firm can show how it reviews and improves customer outcomes.
For related guidance, read Understanding the Affordability and Suitability Rules in Credit Broking.
Complaints can reveal problems in the customer journey.
Review whether your firm has a clear process for:
Credit broking complaints may relate to broker status, unexpected contact, declined finance, lender decisions, fees, commission, data sharing or unclear advertising.
Complaint trends should feed into wider compliance monitoring.
Credit brokers should consider how vulnerable customers are identified and supported.
This may include reviewing:
Vulnerable customer controls should be practical. Staff should know what to do when they identify a customer who may need additional support.
Lead generation can create compliance risk if not properly managed.
Review whether your firm controls:
Third-party content should be approved and monitored. The firm should also check whether promotions remain consistent after publication.
For affiliate and publisher models, read Are You an Affiliate Network or Publisher Facing Issues With Advertiser and Platform Sign-Off?.
A credit broker should have policies and procedures that match the real operating model.
These may include:
Avoid relying on generic policies that do not reflect the customer journey, lender relationships or marketing model.
Staff should understand the firm’s credit broking model and compliance obligations.
Training may cover:
Keep records of who completed training, when it was completed and what topics were covered.
Training should be refreshed when the business model, regulations, systems or customer journey changes.
Compliance needs regular monitoring.
A practical monitoring plan may include:
Monitoring should produce usable management information, not just tick-box evidence.
For audit preparation, read What to Expect During an FCA Compliance Audit as a Credit Broker.
Management information should help the firm understand risk and performance.
Useful credit broking MI may include:
The firm should be able to show that senior people review the information and take action where needed.
If an issue is identified, record what happened next.
Good remediation records may include:
Regulators, principals, lenders and auditors will usually want to see that issues are not only found, but fixed.
Credit broking compliance should be reviewed as rules, guidance and expectations change.
Firms should have a process for monitoring relevant updates, including:
For more guidance, read How to Stay Up to Date With FCA Rules and Regulations as a Credit Broker.
A compliance framework should change when the business changes.
Review compliance before launching:
Commercial changes should not go live before the compliance impact is understood.
For operational guidance, read How FCA Broker Requirements Impact Your Business Operations.
A credit broker should be ready to evidence its compliance framework.
Audit-ready records may include:
For more on regulatory checks, read How to Successfully Pass FCA Regulatory Checks for Credit Broking.
Some firms can manage parts of this checklist internally. Others need specialist support, especially where the model involves direct FCA authorisation, AR or IAR status, multiple lead sources, complex lender relationships, high-volume marketing or outsourced compliance.
Specialist support can help with:
For help choosing support, read Choosing the Right FCA Compliance Consultant for Your Credit Broking Business.
Authorised Compliance provides specialist compliance support for UK credit brokers.
We help firms assess regulatory routes, prepare FCA applications, manage AR and IAR arrangements, review financial promotions, test customer journeys, prepare for audits and build ongoing compliance frameworks.
Our support can include:
We focus on practical credit broking compliance, not generic regulated-firm advice.
You can read more in How Authorised Compliance Helps Credit Brokers Stay FCA-Compliant.
A credit broking compliance checklist is a practical list of areas a credit broker should review, including FCA permissions, broker status, financial promotions, customer journeys, lender relationships, complaints, Consumer Duty, monitoring and audit records.
Many firms carrying out regulated credit broking activity need FCA authorisation or must operate under an appropriate Appointed Representative or Introducer Appointed Representative arrangement. The correct route depends on the business model and activity.
Credit brokers should check that promotions are clear, fair, not misleading, accurate, easy to understand, clear about broker status and consistent with the actual customer journey.
Broker status is important because customers need to understand whether they are dealing with a broker or a lender. Unclear broker positioning can create confusion, complaints and regulatory risk.
Credit brokers should keep records of financial promotion approvals, customer journey reviews, complaints, monitoring activity, training, Consumer Duty evidence, lead source reviews, management information and remediation.
Credit brokers should review compliance regularly and whenever the business model changes. New lenders, adverts, lead sources, introducers, websites or commission arrangements may require review.
A monitoring plan may include financial promotion reviews, customer journey testing, complaints reviews, file reviews, lead source monitoring, Consumer Duty outcome checks and management information review.
Yes. Authorised Compliance can help UK credit brokers review their compliance framework, identify gaps, prepare FCA applications, review financial promotions, test customer journeys, prepare for audits and build ongoing compliance monitoring.
A credit broking compliance checklist should be practical, specific and connected to the real business model.
The strongest firms do not treat compliance as a separate document exercise. They build it into marketing, customer journeys, lender relationships, complaints handling, monitoring and senior management decision-making.
For UK credit brokers, a well-maintained checklist can reduce risk, improve customer understanding and make the business better prepared for FCA reviews, principal oversight, lender due diligence and future 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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