Credit broker compliance audits: what to expect

Agree scope before gathering files

Confirm the reviewer, purpose, activities, period and expected output. A principal review, an independent audit and an FCA request have different authority and scope. The practical steps here describe a typical review, not a mandatory FCA audit sequence.

How evidence is sampled and discussed

Agree how files, calls and customer journeys will be selected. Include exceptions and adverse outcomes as well as routine cases. Record the selection method and limitations so findings are not presented as proof about untested activity. Interviews can explain how work is done; test those explanations against records.

Turn findings into tracked actions

For each finding, identify the evidence, affected control, consequence, owner and target date. Separate factual disagreements from agreed actions. Recheck the corrective action before closing it and retain the supporting record.

Use our regulatory evidence-pack guide for assembling a response and our working compliance checklist for routine monitoring.

What is an FCA compliance audit?

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:

• explains its broker role to customers
• controls financial promotions
• manages customer journeys
• works with lenders or finance providers
• handles commission and disclosure wording
• monitors complaints
• identifies and supports vulnerable customers
• evidences Consumer Duty outcomes
• keeps records
• trains staff
• monitors lead sources, affiliates or introducers
• operates within direct authorisation, AR or IAR scope

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.

Who might carry out the review?

A credit broker may face different types of compliance review.

This could include:

• an FCA review or information request
• an internal compliance audit
• a principal firm review if the business is an Appointed Representative
• an oversight review if the business is an Introducer Appointed Representative
• lender due diligence
• commercial partner review
• platform, affiliate network or advertiser review
• outsourced compliance review

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.

What documents might be requested?

A credit broker should be prepared to provide evidence such as:

• business model summary
• permissions or appointment details
• financial promotion approvals
• website and landing page screenshots
• customer journey maps
• compliance monitoring plan
• monitoring reports
• complaints log
• complaint outcome examples
• Consumer Duty assessment
• vulnerable customer policy
• staff training records
• lender relationship records
• commission disclosure wording
• introducer or affiliate due diligence
• management information
• board or senior management reports
• remediation plans

The exact request will depend on the scope of the review, but a firm that keeps good records will be in a stronger position.

How to prepare before an audit or review

Preparation should start before any formal request arrives.

Useful steps include:

1. Review permissions and scope
   Confirm the firm is operating within direct authorisation, AR status or IAR scope.
2. Check the customer journey
   Review the journey from advert to lender handoff and complaints route.
3. Review financial promotions
   Check all active promotions, landing pages, emails, social posts and affiliate content.
4. Update records
   Make sure approval records, monitoring reports, complaints logs and training evidence are organised.
5. Test Consumer Duty evidence
   Check whether management information shows how customer outcomes are monitored.
6. Review lead sources
   Confirm introducers, affiliates and publishers are approved and monitored.
7. Identify gaps early
   Create a remediation plan for any weaknesses before they become formal findings.
8. Assign responsibility
   Make sure the right people know who will gather documents, answer questions and manage follow-up actions.

For a practical checklist, read Credit Broking Compliance Checklist: What You Need to Know.

What happens after an audit?

After a review, the firm may receive findings, recommendations or requests for further information.

Actions may include:

• updating financial promotions
• improving broker status wording
• strengthening customer journey disclosures
• changing commission disclosure wording
• improving complaints handling
• adding monitoring checks
• updating policies
• improving lead source controls
• completing staff training
• creating a remediation plan
• reporting progress to senior management or the principal firm

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 Preparing for FCA regulatory checks: a credit broker evidence guide.

Common audit mistakes credit brokers make

Common mistakes include:

• trying to prepare evidence only after receiving a request
• relying on generic policies
• having no financial promotion approval records
• failing to check live promotions against approved versions
• not monitoring affiliates or publishers
• unclear broker versus lender wording
• weak Consumer Duty evidence
• incomplete complaints logs
• lack of management information
• no record of remediation
• not updating the framework when the business changes

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.

How Authorised Compliance supports audit preparation

Authorised Compliance supports UK credit brokers with FCA audit and regulatory review preparation.

Our support can include:

• compliance audits
• permissions and scope 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
• monitoring plan reviews
• management information and board reporting support
• remediation planning
• outsourced compliance support

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.

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

Is every compliance audit an FCA inspection?

No. Confirm who commissions and conducts the review. A principal or independent review is different from a review conducted by the FCA.

Does a sample establish that every file is compliant?

No. Record the selection method and limits. Investigate whether findings indicate a wider issue rather than assuming untested files are satisfactory.

When should an audit action be closed?

Record the agreed correction and supporting evidence, then check that the action addressed the finding. A completed task alone does not show that the control works.

See our compliance monitoring support or discuss an audit or review-preparation scope with Authorised Compliance.