MEMA Scope · Assessment
Do financial advisers need FCA authorisation?
A firm gives clients personal recommendations on investments, pensions or savings, and arranges transactions, usually for ongoing fees or commission. Review the initial view below and answer a few questions to refine it.
- Personalised to your business
- FCA rule references
- Follow-up questions available
Potential regulated activity identified
Advising on investments may require FCA authorisation
Giving personal recommendations on investments needs authorisation or appointed representative status.
Route to consider: Direct authorisation (full permission)
Why this was flagged
- 1A personal recommendation on buying, selling or holding a specific investment is advising on investments.
- 2Placing client business through platforms is arranging deals in investments.
Questions still to resolve
Answer to refine the view. The result updates as you go.
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Do you ever make investment decisions for clients without asking them each time?
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Do you hold client money or assets, rather than only paying fees from client accounts?
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Do you also advise on mortgages or insurance?
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Do you operate under a network or principal that takes regulatory responsibility for you?
Regulatory basis to examine
Your next steps
- 1Choose between direct authorisation and appointed representative status
- 2Build the suitability process and client reporting (COBS 9)
- 3Confirm adviser qualifications and competence arrangements
- 4Check which prudential category applies to your firm
Where applications for this model most often fall short
- A documented suitability and research process
- Qualification and supervision evidence for each adviser
- A consistent approach to ongoing advice and charges
This is an initial indication from published FCA material, not an FCA determination or legal advice.
If authorisation is required, check the firm’s governance, policies, resources and application preparedness.
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 gives clients personal recommendations on investments, pensions or savings, and arranges transactions, usually for ongoing fees or commission.
Giving personal recommendations on investments needs authorisation or appointed representative status.
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.
Independent financial adviser or financial planner: frequently asked questions
Do financial advisers need FCA authorisation?
Giving personal recommendations on investments is advising on investments under RAO Art.53 and generally needs authorisation, or appointed representative status, unless an exclusion applies.
Can a financial adviser be an appointed representative?
Yes. An appointed representative may advise under a principal’s permission, subject to the principal’s oversight and the rules in SUP 12.
What could change the answer for financial advisers?
Giving personal recommendations on investments needs authorisation or appointed representative status. It can change depending on the answers to questions such as: Do you ever make investment decisions for clients without asking them each time? Do you hold client money or assets, rather than only paying fees from client accounts? Do you also advise on mortgages or insurance? Do you operate under a network or principal that takes regulatory responsibility for you?
Which FCA rules should financial advisers look at first?
Start with: Advising on investments; Arranging deals in investments; PERG 8: guidance on financial promotion and related activities; Suitability. This is an initial view from published FCA material, not an FCA determination.
What are the first steps for financial advisers?
Choose between direct authorisation and appointed representative status. Build the suitability process and client reporting (COBS 9). Confirm adviser qualifications and competence arrangements. Check which prudential category applies to your firm.
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.
Consumer credit
- Do car dealers offering finance need FCA authorisation?
- Do motor finance brokers need FCA authorisation?
- Do retailers offering buy now pay later need FCA authorisation?
- Do consumer lenders need FCA authorisation?
- Do debt collectors and debt administrators need FCA authorisation?
- Do debt management and debt advice firms need FCA authorisation?
- Do credit lead generators and comparison sites need FCA authorisation?
- Do rent-to-own and vehicle leasing providers need FCA authorisation?
- Do credit brokers introducing customers to lenders need FCA authorisation?
Payments and e-money
- Do payments apps and payment processors need FCA authorisation?
- Do small payment institutions need FCA authorisation?
- Do e-money issuers and digital wallets need FCA authorisation?
- Do agents of payment institutions need FCA authorisation?
- Do open banking providers need FCA authorisation?
- Do money transfer and remittance businesses need FCA authorisation?
- Do marketplaces handling payments need FCA authorisation?
Insurance
Mortgages
Investments and wealth
Other regulated activities
- Do claims management companies need FCA authorisation?
- Do funeral plan providers and sellers need FCA authorisation?
- Do introducers and referral partners need FCA authorisation?
- Do international firms entering the UK need FCA authorisation?
- Do accountants and solicitors giving financial advice need FCA authorisation?
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.
Phone: 0330 133 0811
Email: contact@memaconsultants.com