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.

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Initial viewProvisional assessment

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)

Investment AdviceInvestment Arranging / Dealing

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.

  • ?

    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?

Regulatory basis to examine

Your next steps

  1. 1Choose between direct authorisation and appointed representative status
  2. 2Build the suitability process and client reporting (COBS 9)
  3. 3Confirm adviser qualifications and competence arrangements
  4. 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
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 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.

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.