MEMA Scope · Assessment

Do debt collectors and debt administrators need FCA authorisation?

A firm collects consumer credit debts for lenders, buys debt portfolios, or administers loan books on behalf of lenders. Review the initial view below and answer a few questions to refine it.

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Initial viewProvisional assessment

Potential regulated activity identified

Debt collecting may require FCA authorisation

Taking steps to procure payment of consumer credit debts, or administering agreements for a lender, normally needs authorisation unless an exclusion applies.

Route to consider: Direct authorisation (full permission)

Debt Collecting / Debt Administration

Why this was flagged

  • 1Taking steps to procure payment of a debt due under a regulated credit agreement is debt collecting.
  • 2Performing a lender’s duties or enforcing its rights on its behalf can be debt administration.

Questions still to resolve

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

  • ?

    Do you buy debt portfolios, so that you hold the debt yourself rather than collecting for a client?

  • ?

    Do you advise debtors on how to deal with their debts, or negotiate with other creditors on their behalf?

  • ?

    Are all the debts you collect owed by limited companies or large businesses, not individuals?

  • ?

    Are you the lender, or a member of the lender’s group, collecting only your own debts?Some activities carried on by a person connected to the agreement are excluded.

Regulatory basis to examine

RAO Art.39F Debt collectingDebt collecting (opens in a new tab)RAO Art.39G Debt administrationDebt administration (opens in a new tab)PERG 2.7 Activities: a broad outlinePerimeter guidance (PERG 2.7) (opens in a new tab)CONC 7 Arrears, default and recoveryArrears, default and recovery (opens in a new tab)

Your next steps

  1. 1Confirm whether the underlying agreements are regulated credit agreements
  2. 2Decide which permissions you need: collecting, administration, or both
  3. 3Implement CONC 7 debt collection procedures and vulnerable customer handling
  4. 4Set outsourcing and oversight arrangements with each lender client

Where applications for this model most often fall short

  • A vulnerable customer policy with real case handling evidence
  • Call recording and contact strategy controls
  • Clear lender client contracts and delegated authority limits
Book a free scoping call

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

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 firm collects consumer credit debts for lenders, buys debt portfolios, or administers loan books on behalf of lenders.

Taking steps to procure payment of consumer credit debts, or administering agreements for a lender, normally needs authorisation unless an exclusion applies.

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.

Debt collector or debt administrator: frequently asked questions

Do debt collection agencies need FCA authorisation?

Taking steps to procure payment of a debt due under a regulated credit agreement is debt collecting under RAO Art.39F, which normally needs FCA authorisation unless an exclusion applies.

Does buying debt count as a regulated activity?

Debt purchasers who take assignment of regulated agreements exercise a lender’s rights, which can be regulated in its own right under RAO Art.60B.

What could change the answer for debt collectors and debt administrators?

Taking steps to procure payment of consumer credit debts, or administering agreements for a lender, normally needs authorisation unless an exclusion applies. It can change depending on the answers to questions such as: Do you buy debt portfolios, so that you hold the debt yourself rather than collecting for a client? Do you advise debtors on how to deal with their debts, or negotiate with other creditors on their behalf? Are all the debts you collect owed by limited companies or large businesses, not individuals? Are you the lender, or a member of the lender’s group, collecting only your own debts?

Which FCA rules should debt collectors and debt administrators look at first?

Start with: Debt collecting; Debt administration; Perimeter guidance (PERG 2.7); Arrears, default and recovery. This is an initial view from published FCA material, not an FCA determination.

What are the first steps for debt collectors and debt administrators?

Confirm whether the underlying agreements are regulated credit agreements. Decide which permissions you need: collecting, administration, or both. Implement CONC 7 debt collection procedures and vulnerable customer handling. Set outsourcing and oversight arrangements with each lender client.

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.

Want a consultant to look at your facts?

Book a free scoping call and we will map the permissions, evidence and timeline for your firm.

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