MEMA Scope · Assessment

Do introducers and referral partners need FCA authorisation?

A business introduces its customers or contacts to FCA-regulated firms, such as lenders, mortgage advisers or investment firms, 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

Outcome depends on the detail

Whether introductions are regulated depends on what you introduce customers to

Introductions to lenders, mortgage and insurance intermediaries, and investment firms are treated differently. The introducing exclusion has narrow conditions.

Route to consider: Depends on facts we still need

Why this was flagged

1Effecting introductions for a fee can be a regulated activity, especially for credit, mortgages and insurance.
2An introducing exclusion exists for some investment introductions, but only if all its conditions are met.

Questions still to resolve

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

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Do you introduce customers to lenders or credit brokers?
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Do you introduce customers to mortgage advisers or insurance intermediaries?
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Do you introduce customers to investment advisers or managers?
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Would the authorised firm you introduce to appoint you as its appointed representative?

Regulatory basis to examine

RAO Art.25 Arranging deals in investmentsArranging deals in investments RAO Art.33 Introducing (exclusion)Introducing (exclusion)FSMA 2000 s.39 Exemption of appointed representativesAppointed representatives PERG 2.7 Activities: a broad outlinePerimeter guidance (PERG 2.7)

Your next steps

1List who you introduce customers to and what you do before and after the introduction
2Test each type of introduction against the relevant activity
3Check whether the introducing exclusion applies on its facts
4Consider appointed representative status with the firm you introduce to

Where applications for this model most often fall short

A written description of the referral process
Referral agreements with fees and responsibilities
Evidence of what customers are told about your role

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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 business introduces its customers or contacts to FCA-regulated firms, such as lenders, mortgage advisers or investment firms, in return for a fee or commission.

Introductions to lenders, mortgage and insurance intermediaries, and investment firms are treated differently. The introducing exclusion has narrow conditions.

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.

Introducer or referral partner for regulated firms: frequently asked questions

Do I need FCA authorisation to introduce customers to a regulated firm?

It depends on what you introduce them to. Introductions to lenders are credit broking, and introductions to mortgage, insurance or investment firms can be arranging unless an exclusion applies.

What is the introducing exclusion?

RAO Art.33 excludes certain arrangements to introduce clients to authorised persons, but only where its conditions are met, including a view to independent advice or discretion, and it does not cover everything.

What could change the answer for introducers and referral partners?

Introductions to lenders, mortgage and insurance intermediaries, and investment firms are treated differently. The introducing exclusion has narrow conditions. It can change depending on the answers to questions such as: Do you introduce customers to lenders or credit brokers? Do you introduce customers to mortgage advisers or insurance intermediaries? Do you introduce customers to investment advisers or managers? Would the authorised firm you introduce to appoint you as its appointed representative?

Which FCA rules should introducers and referral partners look at first?

Start with: Arranging deals in investments; Introducing (exclusion); Appointed representatives; Perimeter guidance (PERG 2.7). This is an initial view from published FCA material, not an FCA determination.

What are the first steps for introducers and referral partners?

List who you introduce customers to and what you do before and after the introduction. Test each type of introduction against the relevant activity. Check whether the introducing exclusion applies on its facts. Consider appointed representative status with the firm you introduce to.

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.