MEMA Scope · Assessment

Do credit lead generators and comparison sites need FCA authorisation?

A website or marketing business that collects consumer details or shows loan options and passes customers to lenders in return for a fee or commission. Review the initial view below and answer a few questions to refine it.

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Initial viewProvisional assessment

Potential regulated activity identified

Introducing consumers to lenders may be credit broking

Effecting an introduction to a lender, or presenting or offering credit, can be credit broking. Whether advertising alone is outside depends on the detail of what you do.

Route to consider: Direct authorisation (full permission)

Credit Broking - Full Permission

Why this was flagged

1Effecting an introduction of an individual to a lender is expressly within the credit broking definition.
2Showing specific products and passing on an application can go beyond advertising.

Questions still to resolve

Answer to refine the view. The result updates as you go.

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Do you only display general advertising, with customers choosing to go to the lender themselves and you passing on no customer details?
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Do you pass customer details to a lender or broker for a fee or commission?
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Do you act under an authorised broker that takes regulatory responsibility for you?

Regulatory basis to examine

RAO Art.36A Credit brokingCredit broking PERG 2.7 Activities: a broad outlinePERG 2.7 on credit broking CONC 3 Financial promotionsFinancial promotions FSMA 2000 s.21 Restrictions on financial promotionFinancial promotion restriction

Your next steps

1Map exactly what the visitor sees and what you send to lenders
2Decide whether you present or offer credit, or only advertise
3Check your financial promotions approvals
4Review whether appointed representative status or direct authorisation fits

Where applications for this model most often fall short

Screenshots of the full customer journey and lead transfer
Lender agreements and fee schedules
A financial promotions approval and monitoring process

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This is an initial indication from published FCA material, not an FCA determination or legal advice.

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How Compass helps

Ask about an activity, exclusion or FCA requirement. Answers come only from vetted profiles, FCA Handbook and legislation extracts and MEMA guidance, and every answer cites its source.

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Continue with a more detailed readiness assessment

If authorisation is required, check the firm’s governance, policies, resources and application preparedness.

Will the FCA Authorise Us?

MEMA Scope gives an initial view from published FCA material. It is not legal advice or an FCA determination. Automatic matching and typed questions use AI only to choose a profile and to answer from vetted guidance; the assessment itself is never written by AI.

About this business model

A website or marketing business that collects consumer details or shows loan options and passes customers to lenders in return for a fee or commission.

Effecting an introduction to a lender, or presenting or offering credit, can be credit broking. Whether advertising alone is outside depends on the detail of what you do.

This page gives an initial view from published FCA and legislation sources. It is not an FCA determination or legal advice. Not your business model? Describe your business in MEMA Scope.

Credit lead generator or comparison site: frequently asked questions

Do lead generators for loans need FCA authorisation?

Effecting an introduction of an individual to a lender is within the credit broking definition in RAO Art.36A. Whether your model goes beyond advertising depends on what you present and pass on.

Are comparison sites for credit regulated?

A comparison site that presents or offers specific credit products, or passes the customer to a lender, can be credit broking. The detail of the journey decides the answer.

What could change the answer for credit lead generators and comparison sites?

Effecting an introduction to a lender, or presenting or offering credit, can be credit broking. Whether advertising alone is outside depends on the detail of what you do. It can change depending on the answers to questions such as: Do you only display general advertising, with customers choosing to go to the lender themselves and you passing on no customer details? Do you pass customer details to a lender or broker for a fee or commission? Do you act under an authorised broker that takes regulatory responsibility for you?

Which FCA rules should credit lead generators and comparison sites look at first?

Start with: Credit broking; PERG 2.7 on credit broking; Financial promotions; Financial promotion restriction. This is an initial view from published FCA material, not an FCA determination.

What are the first steps for credit lead generators and comparison sites?

Map exactly what the visitor sees and what you send to lenders. Decide whether you present or offer credit, or only advertise. Check your financial promotions approvals. Review whether appointed representative status or direct authorisation fits.

Businesses we check

MEMA Scope covers 32 common business models. Each page explains whether that kind of business may need FCA authorisation, the rules to look at and the routes to consider.