Credit broking is a regulated activity that can apply to many different business models in the UK.
It is not limited to traditional finance brokers. A retailer, platform, lead generation business, publisher, introducer, affiliate network or service provider may need to consider credit broking compliance if it introduces customers to lenders, passes finance enquiries to another firm or promotes credit options.
The key question is not what the business calls itself. The key question is what the business actually does in the customer journey.
This guide explains what credit broking is, when FCA permissions may be needed and how firms can think about the right route to market.
Credit broking usually involves introducing customers to lenders or helping customers access credit options.
In practice, credit broking may include:
A credit broker does not necessarily provide the credit. In many models, the broker introduces the customer to a lender or finance provider that may make the lending decision.
For a wider industry view, read Credit Broking: A Complete Industry Overview.
The difference between a credit broker and a lender is central to compliance.
A lender provides the credit. A broker introduces customers to lenders or finance providers.
Customers should understand:
The FCA’s credit broking rules say brokers need to make clear in advertising that they are brokers and not lenders.
For a detailed explanation, read Credit Broker vs Lender: Key Differences Explained.
Credit broking rules may be relevant to more businesses than expected.
Examples include:
The activity and customer journey matter more than the business description.
A business should assess whether it is introducing customers to lenders, distributing credit-related promotions or playing a role in the finance journey.
For more on businesses offering finance, read Offering Finance to Customers in the UK: What Businesses Need to Know.
A firm may need FCA authorisation if it carries out regulated credit broking activity.
The position depends on:
Businesses offering credit or financing to customers should check whether they need FCA authorisation for regulated consumer credit activities, including arranging credit for other people.
For more on why authorisation matters, read Why FCA Authorisation Matters for Credit Brokers.
Direct FCA authorisation may be suitable where the firm wants to hold its own permissions and take direct responsibility for its credit broking activity.
A directly authorised credit broker is responsible for maintaining a compliance framework covering:
Direct authorisation can offer greater control, but it also requires suitable systems, resources and evidence.
For a practical guide, read How to Get FCA Authorisation as a Credit Broker: Step-by-Step Guide.
Consumer credit firms applying directly may need to understand whether Limited Permission or Full Permission applies.
The right category depends on the activity carried out.
A credit broking business should review:
The permission route should match the real activity. Choosing the wrong category can create delay, rework or regulatory risk.
For more on route planning, read FCA Authorisation Routes for Credit Brokers: Direct Authorisation, AR and IAR Status.
Appointed Representative status may be suitable where a firm operates under the permissions and oversight of an authorised principal firm.
This route may work for some credit broking businesses, but it still requires control.
An AR arrangement should include:
The principal firm is responsible for the regulated activity carried out by its AR within the appointment framework, so oversight needs to be real and documented.
Introducer Appointed Representative status is narrower than full AR status.
It may be suitable where the business only introduces customers or distributes approved financial promotions.
An IAR should understand:
IAR status may not be enough if the firm is actively arranging finance, giving detailed product information, controlling lender selection or operating a broader credit broking journey.
The right route depends on the real business model.
Before choosing direct authorisation, AR status or IAR status, ask:
The best route is not always the fastest or cheapest route. It is the route that fits the activity and can be operated properly.
For more on costs, read How Much Does It Cost to Become an FCA Authorised Credit Broker?.
Financial promotions are a major compliance area for credit brokers.
They may include:
CONC 3 includes rules on financial promotions and communications, including the clear, fair and not misleading rule.
Credit brokers should review promotions before they go live and keep records of approvals.
For a detailed guide, read How to Advertise as a Credit Broker Without Breaking FCA Rules.
Credit broking compliance should be reviewed from the customer’s perspective.
A customer journey review should cover:
The customer should understand who they are dealing with, what service is being provided, who may receive their details, who makes the lending decision and how to complain.
For a practical checklist, read Credit Broking Compliance Checklist: What You Need to Know.
Lead generation can fall within credit broking where it involves introducing customers to lenders, passing finance enquiries or distributing credit-related financial promotions.
Lead generation controls should cover:
Lead generation should be treated as part of the customer journey, not only as marketing.
For more detail, read Lead Generation in FCA-Compliant Credit Broking: What You Need to Know.
Credit brokers often work with lenders, finance providers or selected panels.
Customers should receive clear information where relevant about:
Avoid broad claims such as “whole of market” unless they can be supported by the real business model.
Consumer Duty is highly relevant to credit broking because brokers often influence the customer’s understanding before they reach a lender.
A credit broker should monitor:
The firm should be able to show how it identifies risks and improves the journey over time.
For related guidance, read Understanding the Affordability and Suitability Rules in Credit Broking.
Complaints can reveal weaknesses in a credit broking model.
Common complaint themes may include:
A credit broker should log complaints, investigate them, review root causes and use them to improve customer journeys and promotions.
Vulnerable customer support should also be practical, with staff training, escalation routes and monitoring.
Credit brokers should keep evidence of how they manage compliance.
Useful records include:
These records support FCA reviews, lender due diligence, principal oversight, platform checks and internal audits.
For audit preparation, read What to Expect During an FCA Compliance Audit as a Credit Broker.
Common mistakes include:
For a detailed guide, read The Biggest Mistakes Businesses Make When Understanding Credit Broking.
Authorised Compliance helps UK firms understand credit broking activity, permissions and the right route to market.
Our support can include:
We focus on practical credit broking compliance, helping firms build models that are clear for customers, credible for partners and properly controlled.
You can read more in How Authorised Compliance Helps Credit Brokers Stay FCA-Compliant.
Credit broking usually involves introducing customers to lenders or finance providers, helping customers access credit options or passing finance enquiries to another firm.
Yes. Many firms carrying out regulated credit broking activity need FCA authorisation or must operate under an appropriate Appointed Representative or Introducer Appointed Representative arrangement.
It may still need FCA authorisation or another compliant route if it introduces customers to lenders, passes finance enquiries, distributes credit-related promotions or receives commission from introductions.
A lender provides the credit. A broker introduces customers to lenders or finance providers. Customers should understand which role the firm performs.
An Appointed Representative carries out regulated activity under the permissions and oversight of an authorised principal firm.
An Introducer Appointed Representative has a narrower role, usually involving introductions or distributing approved financial promotions.
Yes. Credit broker financial promotions should be clear, fair and not misleading. They should make broker status clear where relevant and match the real customer journey.
Yes. Authorised Compliance supports firms with credit broking activity reviews, permissions analysis, FCA applications, AR and IAR route assessment, financial promotion checks and customer journey testing.
Credit broking can apply to many more businesses than traditional finance brokers.
If a business introduces customers to lenders, passes finance enquiries, promotes credit options or earns income from finance introductions, it should review whether credit broking rules apply.
The right approach starts with the real activity and customer journey. From there, firms can assess whether direct FCA authorisation, AR status, IAR status or another compliant route is the best fit.
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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