The FCA’s Regulatory Guide for Credit Brokers: A Section-by-Section Compliance Playbook

“The FCA published a plain-English guide for smaller credit brokers covering nine areas — from getting your permissions right to overseeing appointed representatives. Here’s what each section requires, and how to evidence it.”

Credit broking is one of the most heavily populated corners of the FCA’s register — tens of thousands of firms, from motor dealers and retailers offering point-of-sale finance to standalone brokers arranging loans. Most are small. Many treat regulation as something to survive once a year rather than evidence every day.

The FCA knows this, which is why it published a plain-English Regulatory guide for credit brokers aimed squarely at smaller firms. It walks through nine areas, from getting your permissions right to overseeing appointed representatives.

One theme recurs in almost every one of them: the Consumer Duty (PRIN 2A). The FCA comes back to it constantly — in how you advertise credit, how you explain it, how you treat vulnerable customers, and how you evidence the outcomes they actually receive. Treat it as the spine of the guide, not a separate chapter.

This article takes each section in turn: what the FCA expects, and how RegTechPRO helps you meet the obligation and prove it. It is a practitioner’s read of the guide, not legal advice — rule references (CONC, SYSC, DISP, SUP, PRIN 2A) are there so you can go to the source.

1. Running your credit broking business: the basics

What the FCA expects. Credit broking is a regulated activity under Article 36A of the Regulated Activities Order. You cannot carry it on unless you are FCA authorised with the right permission — or an appointed representative of a principal who is. The FCA distinguishes limited permission brokers, where broking is secondary to your main business (a retailer arranging finance, say), from full permission brokers, where it is the main event. Your permission must match what you actually do. You must also meet the Threshold Conditions (COND) on an ongoing basis, comply with the Principles for Businesses, including the Consumer Duty (PRIN 2A), and keep your authorisation and fees current.

How RegTechPRO helps. The FCA Application Tracker is built for exactly this. Whether you are seeking authorisation or varying your permission, it gives you an activity-scoped document checklist — around 41 items for full-permission credit broking — plus Anna’s Application Requirements Report, an eight-section blueprint written to RAO-article precision, and a 180-day assessment-window tracker so you always know where the application stands. Once authorised, Firm Compliance holds your permissions, firm records and FCA filings in one place, and the Compliance Hub turns each ongoing obligation into a tracked, evidenced task.

2. Promoting your business and finding customers

What the FCA expects. Every financial promotion must be clear, fair and not misleading (CONC 3.3). If you quote an interest rate or any amount relating to the cost of credit, you must show a representative example with the representative APR given no less prominence (CONC 3.5). And you are responsible for promotions made on your behalf — by lead generators, affiliates and introducers, across every channel including social media (the FCA’s FG24/1 guidance applies). You need a documented sign-off process and you must keep records of what you approved and when. The Consumer Duty’s consumer-understanding outcome (PRIN 2A.5) sits on top: communications must equip customers to make good decisions.

How RegTechPRO helps. Policy Studio drafts your financial promotions policy — approval workflow, social-media standards, affiliate oversight — then Anna scores it out of ten and turns each commitment into a trackable task. The Compliance Monitoring Plan carries CONC 3 review templates so you can test live promotions against the rules on a schedule and evidence each review. And the Document Library retains every approved promotion with version history and provenance, so when a supervisor asks what you signed off and when, the answer is one search away. And because PRIN 2A.5 makes clear communication a measurable outcome, the Consumer Duty Hub carries a dedicated consumer-understanding assessment — so you can show your promotions actually helped customers decide, not just that they were approved.

3. Dealing with customers

What the FCA expects. You must act honestly, fairly and professionally in your customers’ interests (CONC 2). Before a credit agreement is entered into, give adequate explanations and pre-contract information so the customer can judge whether it suits them (CONC 4.2). Any fee you charge the customer must be disclosed and agreed in writing, in good time (CONC 4.4). You must disclose the existence — and where relevant the nature — of any commission that could affect your impartiality (CONC 4.5), an area under intense FCA scrutiny since the motor-finance commission reviews. Over all of it sits the Consumer Duty: deliver good outcomes on products and services, price and value, consumer understanding and consumer support (PRIN 2A.3–2A.6), act in good faith, avoid foreseeable harm, and take particular care with vulnerable customers (FG21/1). And it does not stop at the point of sale: you must monitor the outcomes your customers actually receive and report them to your board every year (PRIN 2A.8).

How RegTechPRO helps. The Consumer Duty Hub is a complete PRIN 2A system: firm-level assessments across 15 areas, per-product fair-value reviews, vulnerable-customer consideration, monthly MI, a board-challenge record, and a 29-page Anna-generated annual board report mapped to FG22/5. Policy Studio covers the surrounding policies — commission disclosure, conflicts of interest, fees and vulnerability — drafted, scored and operationalised into tasks. And the Compliance Monitoring Plan provides the CONC conduct-review templates to test it all in practice.

4. Making sure the right people are in the right roles

What the FCA expects. The Senior Managers and Certification Regime applies to credit brokers (most are limited-scope or core firms). Senior managers need FCA approval and a Statement of Responsibilities; certification staff must be assessed as fit and proper at least annually (FIT); and the Conduct Rules (COCON) reach almost everyone in the firm, with training to match. Staff who deal with customers must be competent (SYSC 5 and the training-and-competence rules), and your Directory submissions must be kept up to date.

How RegTechPRO helps. People Compliance is the SM&CR module built for this: dedicated editors for each person type, Statements of Responsibilities, a 55-question Form A Section 5 fitness-and-propriety assessment, Conduct Rules training tracking, a Certificate of Competence with 12-month validity, and CPD measured against the FCA’s 35-hour benchmark. Every appointment and annual attestation leaves an evidence trail.

5. What checks does your business need to have in place

What the FCA expects. You must establish and maintain systems and controls proportionate to your size, including a compliance monitoring programme that actually runs (SYSC 6.1), with clear senior-management responsibility for oversight. You need to manage conflicts of interest, guard against financial crime and fraud — some brokers fall within the Money Laundering Regulations 2017, and all sit under the Proceeds of Crime Act and the failure-to-prevent-fraud offence introduced by ECCTA 2023 — and keep adequate records to demonstrate compliance.

How RegTechPRO helps. The Compliance Monitoring Plan turns SYSC 6.1 from an aspiration into a schedule: 1,102 expert-authored review templates across 74 FCA-aligned categories, with a five-year forward Year view so monitoring is planned, dated and evidenced rather than ad hoc. The Risk Management Hub runs a 5×5 register with three scores per risk — inherent, residual and risk-appetite — plus a live heat map. Where financial-crime risk applies, the Financial Crime Suite adds AML, sanctions and fraud controls with a 132-question gap analysis. The Compliance Hub ties it together with tasks, a maker-checker workflow and a full audit trail.

6. Handling complaints when things go wrong

What the FCA expects. You need a written complaints-handling procedure that customers can find and use (DISP 1). Complaints must be investigated fairly and answered with a final response within eight weeks — or a summary resolution communication if you resolve within three business days. Eligible complainants must be told of their right to refer the matter to the Financial Ombudsman Service. You should carry out root-cause analysis, feed the lessons back into the business, and report your complaints data to the FCA (publishing it too if you cross the reporting threshold).

How RegTechPRO helps. The Compliance Hub gives you a complaints register with maker-checker sign-off and a timestamped audit trail, so every complaint is tracked against the eight-week clock. The Compliance Monitoring Plan includes a DISP complaints-handling review template to test the process itself. And complaints MI and root-cause analysis flow into the MI Dashboard and your Consumer Duty board report — turning individual grievances into the outcome data the FCA expects to see.

7. Updating us

What the FCA expects. Keep the FCA informed. Submit your regulatory returns accurately and on time through RegData (consumer-credit firms file the CCR returns); notify the regulator promptly of significant events and breaches under SUP 15, since Principle 11 requires you to be open and cooperative; and seek approval for any change in control (SUP 11). Keep your standing data and Directory current, vary your permissions when your activities change, and pay your fees.

How RegTechPRO helps. Firm Compliance holds your standing data, permissions, AR network and FCA filings as a single source of truth, so what you report matches what you do. The FCA Application Tracker manages variations of permission and individual registrations through their full lifecycle. The Compliance Hub schedules every reporting deadline as a recurring task so a RegData return is never missed, and Horizon Scanning — a live feed from 13 UK regulators — flags the rule changes that should trigger a notification or a permission change in the first place.

8. How the FCA supervises firms

What the FCA expects. Supervision is proportionate to your size, but it is increasingly data-led. Expect information requests, surveys and thematic reviews, with the agenda set by the FCA’s consumer-finance priorities — affordability, fair value, the treatment of customers in financial difficulty, and commission. The common thread is that you must be able to evidence your compliance quickly, not reconstruct it after the request lands.

How RegTechPRO helps. This is what the platform is for. The MI Dashboard gives you a real-time, RAG-scored picture of compliance health across every module. Because consumer-finance supervision is Consumer Duty-led, the Consumer Duty Hub’s outcomes MI and annual board report are usually the first evidence a supervisor asks to see. The Document Library is a cross-module evidence vault that preserves where each document came from. Anna AI — grounded in 150+ expert-authored documents, the FCA handbook and 25+ years of compliance experience — turns your live data into board-ready, source-cited reports. And every action carries an audit trail. When the FCA asks, you answer in minutes, not weeks.

9. Using appointed representatives

What the FCA expects. If you appoint ARs or introducer ARs, you are fully responsible for the regulated activities they carry on. That means robust pre-appointment due diligence, a written agreement, genuine ongoing oversight and monitoring, and at least an annual review. The FCA’s enhanced AR regime (PS22/11) raised the bar: principals must collect more data on their ARs, complete an annual self-assessment, and notify the FCA earlier and in more detail. And customers must always know who they are dealing with.

How RegTechPRO helps. The SUP 12 AR-oversight tooling in Firm Compliance is built for principals: a 17-item SUP 12 framework spanning pre-appointment due diligence, ongoing monitoring and record-keeping; a canonical 10-document due diligence pack; a rolling 12-month KPI matrix for each AR; automatic alerts 90 days before an agreement expires; and a branded, FCA-ready oversight report you can export on demand. The platform-wide workflow switcher lets you oversee each AR in its own ring-fenced view — so one principal can supervise a whole network without the data ever bleeding together.

The FCA’s guide is, in effect, a map of everything a credit broker has to get right. None of it is optional — but none of it has to live in scattered spreadsheets and a once-a-year consultant visit either. Structure each obligation, capture the evidence as you go, and the day the FCA calls becomes a five-minute job instead of a five-day scramble. That is the whole idea behind RegTechPRO.

See how RegTechPRO handles FCA compliance — book a free 20-minute demo → regtechpro.co.uk/book-a-consultation

FCA guidance: https://www.fca.org.uk/firms/regulatory-guide-credit-brokers

Laurence Rixon is the founder of RegTechPRO, an FCA compliance platform built for small and mid-sized financial services firms. With 25+ years of compliance experience across some of the most recognisable brands in financial services, he built RegTechPRO to solve the exact problems he saw firms struggling with every day.