Preparing for FCA regulatory checks: a credit broker evidence guide

If the FCA knocked on your door today, what evidence could you show?

Start with an evidence index, not a last-minute collection of policies. This practical readiness sequence helps organise a response; it is not an FCA-prescribed checklist or a guarantee of a successful review.

1. Define the request. Record the activities, period, documents and response deadline in scope. Assign one response owner and record questions that need clarification.
2. Map the evidence. Connect permissions and customer journeys to current promotions, sampled files, complaints, outcome monitoring, training and oversight records.
3. Test the explanation. Select examples and check whether actual practice supports the policy and the figures. Record gaps and contradictory evidence rather than hiding them.
4. Plan corrections. Give each finding an owner, action, target date and evidence of completion. Assess whether customers may be affected and escalate through the appropriate process.
5. Quality-check the response. Confirm the index, versions, dates and explanations agree. Keep the submitted pack and a log of follow-up questions.

For how a review is conducted, read what to expect from a credit broker compliance audit. For recurring controls, use the working compliance checklist.

Build the pack around the request

Record who requested the information, which entity and activities it concerns, the period covered and the requested response date. An FCA request, principal review and independent audit are not interchangeable. Follow the actual request and applicable requirements.

Create an evidence index

Add a file location, version, named owner and response reference for every entry. These are suggested organisation fields, not an FCA-prescribed pack. Do not fill evidence gaps with an unsupported assurance.

For the review process, see Credit broker compliance audits: what to expect. For recurring checks, use our working compliance checklist.

What are FCA regulatory checks?

FCA regulatory checks can include reviews, questions, information requests, supervisory engagement or thematic work.

A credit broker may also face similar checks from a principal firm, lender, platform, affiliate network or commercial partner. Even where the FCA is not directly involved, the evidence required can be similar.

A review may look at whether the firm:

• has the right permissions or appointment scope
• explains its broker role clearly
• controls financial promotions
• reviews customer journeys
• monitors complaints
• manages lead sources and introducers
• discloses lender relationships appropriately
• considers vulnerable customers
• evidences Consumer Duty outcomes
• keeps accurate records
• acts on compliance findings
• reports issues to senior management

For a deeper explanation of what may happen during a review, read Credit broker compliance audits: what to expect.

Prepare an evidence pack

A practical evidence pack can make regulatory checks easier to manage.

It may include:

• permissions or appointment summary
• business model summary
• customer journey map
• financial promotion register
• approved promotions and screenshots
• complaints log
• Consumer Duty evidence
• vulnerable customer process
• monitoring plan
• monitoring reports
• lead source register
• lender relationship summary
• commission disclosure wording
• staff training records
• management information
• remediation tracker

The evidence pack should be current, specific and aligned with the business model.

Run an internal review before a formal check

Credit brokers should not wait for a formal request before reviewing their framework.

An internal review can test whether the business is ready.

Ask:

• are our permissions still correct?
• is our broker status clear?
• are all promotions approved and recorded?
• does the customer journey match our policies?
• are commission disclosures accurate?
• do we monitor lead sources?
• are complaints reviewed for root cause?
• do we have Consumer Duty evidence?
• is MI being reviewed?
• are remediation actions completed?
• can we produce records quickly?

For a fuller audit-style guide, read Credit broker compliance audits: what to expect.

Avoid common mistakes during regulatory checks

Common mistakes include:

• preparing only after the FCA asks questions
• relying on generic policies
• having no financial promotion approval records
• unclear broker versus lender wording
• weak lead source monitoring
• poor complaints root cause analysis
• no Consumer Duty evidence
• outdated customer journey maps
• missing training records
• management information that is not reviewed
• remediation actions left incomplete
• inconsistent answers across documents

For more detail, read Common Compliance Mistakes Credit Brokers Make and How to Avoid Them.

What to do if issues are found

If a regulatory check identifies issues, the firm should act quickly and proportionately.

This may involve:

• updating financial promotions
• changing broker status wording
• improving customer journey disclosures
• strengthening lead source controls
• updating commission disclosure wording
• improving complaints handling
• adding Consumer Duty monitoring
• completing staff training
• updating policies
• reviewing customer impact
• creating a remediation plan
• tracking actions to completion

The response should be structured. It should show what the issue was, what caused it, what customer impact may exist and what has been done to address it.

How Authorised Compliance supports regulatory check preparation

Authorised Compliance supports UK credit brokers with practical preparation for FCA regulatory checks, principal reviews, lender due diligence and internal audits.

Our support can include:

• permissions and scope reviews
• business model reviews
• customer journey testing
• financial promotion reviews
• broker versus lender wording checks
• lead generation reviews
• Consumer Duty assessments
• complaints process reviews
• lender relationship and commission disclosure reviews
• vulnerable customer reviews
• monitoring plan development
• management information review
• evidence pack preparation
• remediation planning
• outsourced compliance support

We focus on helping credit brokers build controlled, commercially workable models that can be evidenced when questions are asked.

You can read more in How Authorised Compliance Helps Credit Brokers Stay FCA-Compliant and Choosing the Right FCA Compliance Consultant for Your Credit Broking Business.

Primary sources and scope checks

Check the current requirements against the activity, customer, agreement and permissions of the particular firm. These primary sources support a scope and control review; a generic checklist does not establish compliance in every model.

• FCA: Consumer credit broker authorisation
• FCA Handbook: Credit-broking conduct
• FCA: Consumer Duty information for firms

Frequently asked questions

What should an evidence index contain?

Link each request to the relevant record, version, period and owner. Note gaps openly and retain the submitted response.

What if requested evidence is missing?

Establish the facts, record the gap and arrange an accurate response through the responsible person. Do not substitute an unsupported compliance claim.

Does a complete pack guarantee a satisfactory outcome?

No. The reviewer assesses the business and evidence. A well-organised pack helps explain the position but cannot guarantee the decision.

For follow-up work, see our regulatory remediation support and compliance monitoring support, or contact Authorised Compliance to discuss your review requirements.