An FCA compliance audit or regulatory review can feel challenging if your credit broking business is not prepared.
The good news is that most of the areas likely to be reviewed are things a well-run credit broker should already be monitoring: permissions, customer journeys, financial promotions, lender relationships, commission disclosures, complaints, Consumer Duty outcomes, records and ongoing compliance controls.
For credit brokers, the key is evidence. It is not enough to say that the firm treats customers fairly or reviews financial promotions. You need to be able to show what you do, how often you do it, what you found and what changed as a result.
This guide explains what credit brokers should expect during a compliance audit or review, and how to prepare properly.
An FCA compliance audit is a review of whether a regulated firm is operating in line with its permissions, obligations and customer outcome expectations.
For credit brokers, a review may look at how the firm:
Not every review will look the same. The scope may depend on the firm’s business model, risk profile, permissions, complaints, growth, marketing activity, AR/IAR arrangements or previous issues.
For a broader overview of the compliance framework, read What Is Credit Broking Compliance? A Beginner’s Guide.
A credit broker may face different types of compliance review.
This could include:
The reviewer may differ, but the evidence needed is often similar. A firm should be able to show how it controls the activity it carries out.
Credit brokers may be reviewed for many reasons.
A review may be triggered by:
A review should not be treated only as a threat. It can also be a useful way to identify gaps, improve controls and strengthen the business.
For common issues that can lead to concern, read Common Compliance Mistakes Credit Brokers Make and How to Avoid Them.
The first area likely to be reviewed is whether the firm has the right regulatory route for its activity.
The reviewer may consider whether the business is:
For directly authorised firms, this may involve checking whether the firm’s permissions match its current activity.
For ARs and IARs, this may involve checking whether the firm is staying within the scope of the appointment and whether the principal’s approval and oversight process is being followed.
For more on route options, read Why FCA Authorisation Matters for Credit Brokers and Advanced Strategies for Mastering What Are the Two Types of FCA Authorisation for Firms.
A compliance audit will usually look at how the business actually works.
This may include reviewing:
For credit brokers, customer journey review is particularly important because many compliance risks happen before a customer reaches a lender.
A reviewer may test whether customers understand:
For more detail, read Credit Broker vs Lender: Key Differences Explained.
Financial promotions are one of the most important audit areas for credit brokers.
The review may cover:
A reviewer may look for evidence that promotions are clear, fair and not misleading, and that the broker role is clear where the firm is acting as a broker.
They may also check whether:
For a deeper guide, read How to Advertise as a Credit Broker Without Breaking FCA Rules.
Credit brokers should be clear that they are brokers, not lenders, where that is the role they perform.
During a review, the firm’s customer-facing wording may be checked carefully.
This could include:
The issue is not only whether “broker” appears somewhere on the page. The question is whether the overall impression is clear for the customer.
A reviewer may consider whether the firm uses lender-style language, implies guaranteed acceptance, or fails to explain who makes the lending decision.
Lead generation can create significant compliance risk if not properly controlled.
An audit may review:
If a credit broker relies on third parties, it should be able to show how those relationships are controlled.
This may include due diligence records, approved promotional material, monitoring reports, screenshots, complaints data and escalation records.
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.
A review may look at whether customer communications explain those relationships properly.
This may include:
The homepage copy deck recommends avoiding claims that are difficult to evidence, such as “best in the business” or “whole of market” unless the position can be supported. Safer language should be specific and evidence-based.
A compliance audit may look at how the firm monitors customer outcomes.
Consumer Duty expects firms to act to deliver good outcomes for retail customers, and FCA material describes the Duty as moving beyond compliance checklists into embedding fairness, transparency and customer-centricity into interactions.
For credit brokers, outcome evidence may include:
The firm should be able to show how it identifies potential harm, what management information it reviews and how issues are escalated.
For related guidance, read Understanding the Affordability and Suitability Rules in Credit Broking.
Complaints are an important source of compliance evidence.
A review may look at:
Credit broking complaints may relate to broker status, unwanted contact, data sharing, fees, commission, lender decisions, declined applications or confusion about who is responsible.
A firm should not treat complaints only as individual cases. Complaint trends should feed into monitoring and improvement.
Policies should reflect the real business model.
A compliance audit may check whether the firm has relevant policies and whether staff understand them.
This may include:
A generic policy pack is unlikely to be enough if it does not match the customer journey, marketing model and lender relationships.
A strong credit broking compliance framework should include regular monitoring.
An audit may review whether the firm monitors:
Management information should help the firm identify risks and take action. It should not be produced only for record keeping.
A reviewer may ask what issues have been identified, what decisions were made and what improvements followed.
For ongoing compliance planning, read How Much Does It Cost to Maintain FCA Compliance for Credit Brokers?.
A credit broker should be prepared to provide evidence such as:
The exact request will depend on the scope of the review, but a firm that keeps good records will be in a stronger position.
Preparation should start before any formal request arrives.
Useful steps include:
For a practical checklist, read Credit Broking Compliance Checklist: What You Need to Know.
After a review, the firm may receive findings, recommendations or requests for further information.
Actions may include:
The most important point is to act on findings. A review is much less valuable if issues are identified but not followed through.
For more on regulatory checks, read How to Successfully Pass FCA Regulatory Checks for Credit Broking.
Common mistakes include:
These issues are avoidable with regular monitoring and clear ownership.
For more detail, read Common Compliance Mistakes Credit Brokers Make and How to Avoid Them.
Authorised Compliance supports UK credit brokers with FCA audit and regulatory review preparation.
Our support can include:
We help firms identify gaps, organise evidence and build practical controls that support day-to-day credit broking activity.
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.
An FCA compliance audit or review checks whether a credit broker is operating within its permissions and maintaining appropriate controls around customer journeys, financial promotions, complaints, Consumer Duty, record keeping and ongoing monitoring.
A credit broker may need financial promotion approvals, customer journey maps, complaints logs, monitoring reports, training records, Consumer Duty evidence, lender relationship records, commission disclosure wording and remediation plans.
Financial promotions are likely to be a key area of review. Websites, landing pages, adverts, emails, social posts, scripts and affiliate content should be clear, fair, not misleading and properly approved where required.
Broker versus lender wording is important because customers need to understand whether they are dealing with a broker or a lender. Unclear wording can create customer confusion, complaints and regulatory risk.
Credit brokers can prepare by reviewing permissions, customer journeys, financial promotions, complaints records, Consumer Duty evidence, lead source controls, monitoring reports and management information.
If an audit finds issues, the firm may need to update promotions, improve disclosures, strengthen monitoring, update policies, complete training, improve complaints handling or implement a remediation plan.
Credit brokers should review compliance regularly and whenever the business model changes. Financial promotions, customer journeys, lead sources, complaints and customer outcomes should be monitored on an ongoing basis.
Yes. Authorised Compliance supports UK credit brokers with compliance audits, FCA review preparation, financial promotion checks, customer journey testing, Consumer Duty assessments, complaints reviews and remediation planning.
A compliance audit should not be seen as a one-off event. It is a test of whether the firm’s controls are working in practice.
For credit brokers, the strongest preparation is ongoing evidence. Clear permissions, controlled promotions, tested customer journeys, good complaints records, Consumer Duty monitoring and practical management information all help show that the firm is operating properly.
A well-prepared credit broker should be able to explain what it does, evidence how it controls risk and show how it improves customer outcomes over time.
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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