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Which business sectors need help with FCA authorisation questions?

Short answer

Perimeter questions come up wherever a business touches money, credit, payments, investment, insurance or crypto, or markets those things. These are the sectors and sub-sectors we hear from most, with the question each one usually needs answering.

The answer always depends on the detail of your model, your customers and your marketing. That is what a written opinion applies to your facts.

Updated

Lending and credit

Business lenders and alternative finance

Lending to limited companies is usually outside the consumer credit regime. Lending to sole traders, partnerships of two or three partners and some unincorporated bodies can be regulated unless an exemption applies, such as the one for business loans over £25,000. Business lending

Bridging and property finance

A bridging loan secured on a home that the borrower or a family member lives in can be a regulated mortgage contract even when the money is for business. Loans to companies secured on investment property are usually outside, but the borrower and the security both need checking.

Asset finance and leasing

Leasing equipment or vehicles to companies is generally unregulated. Hiring goods to individuals and small partnerships can be consumer hire, which is a regulated activity with its own set of exemptions.

Invoice and trade finance

Invoice finance and factoring for limited companies usually sit outside consumer credit. Facilities for sole traders or small partnerships, and arrangements that work more like a loan than a purchase of debts, need a closer look.

Debt solutions and debt collection

Debt counselling and debt adjusting for consumers are regulated activities. Collecting debts owed under regulated credit agreements is regulated too, while collecting purely commercial debts from companies usually is not.

Brokers, introducers and lead generation

Commercial finance brokers

Brokers who only arrange finance for limited companies are often outside the credit broking rules. Sole trader clients, consumer hire or a home given as security can bring regulated activity in. Commercial finance brokers

Introducers and affiliates

Introducing individuals or small partnerships to a lender or broker is usually credit broking, whether or not you are paid commission and whether or not the loan goes ahead. Introductions of companies are treated differently. Loan introducers

Lead generators and comparison sites

Selling leads for loans, mortgages, insurance or investments can be a regulated activity in itself, and the adverts that collect the leads are a separate financial promotion question. Lead generation

Mortgage and protection introducers

Estate agents, accountants and others who pass clients to a mortgage broker can sometimes rely on a narrow introducer exclusion if they only make the introduction and meet its conditions. Protection and other insurance introductions follow the insurance distribution rules. Insurance introductions

Payments and fintech

Payment platforms and marketplaces

Platforms that collect money from buyers and pass it to sellers may be providing payment services. The commercial agent exclusion can help, but it is narrow and often hard to rely on when the platform acts for both sides. Payments and e-money

Prepaid cards, vouchers and gift cards

Issuing stored value can be issuing e-money. Cards and vouchers usable only within a limited network of merchants may fall within the limited network exclusion, which has a notification requirement once transactions pass a set level.

Open banking and data businesses

Accessing customer bank accounts to read data is an account information service, which usually needs FCA registration. Initiating payments from a customer’s account is a payment initiation service, which needs authorisation.

Software, SaaS and banking as a service

Supplying technology to regulated firms is usually outside the perimeter. If your platform holds client funds, matches lenders with borrowers or makes personal recommendations, you may be carrying on the regulated activity yourself. Fintech software and platforms

Embedded finance and white label products

Offering a partner’s financial product under your own brand raises two questions: whether you are arranging or broking it, and whether your marketing of it is a financial promotion that the authorised partner needs to approve.

Investment and fundraising

Startups and scaleups raising money

Pitch decks, investor emails and crowdfunding pages are usually financial promotions when they invite investment in shares or bonds. Companies raising money normally rely on investor exemptions, approval by an authorised firm or an authorised platform. Fundraising and investor materials

Property syndicates and developers raising funds

Pooling investors’ money into a property project where they do not have day to day control can create a collective investment scheme, and operating one is regulated. The structure decides it. Property and investment schemes

Crowdfunding and investment platforms

Running an investment-based or loan-based crowdfunding platform is regulated. Donation and reward-based crowdfunding generally is not, unless the rewards start to look like a financial return.

Deal introducers and investment clubs

Introducing investors to a specific deal can be arranging deals in investments. The introducing exclusion is narrow and does not cover most introductions to a single opportunity. Investment introductions

Family offices

A family office managing its own family’s assets is often outside the perimeter. Managing money for unconnected families, pooling investments with outsiders or advising others can change that.

Fund managers and fund launches

Managing an investment fund is usually regulated. Smaller managers may be able to register rather than seek full authorisation, and some launch as an appointed representative of a hosting firm. Your options if you are inside the perimeter

Crypto and digital assets

Exchanges, brokers and trading platforms

Cryptoasset exchanges and brokers currently register with the FCA under the Money Laundering Regulations. Under the new regime, whose authorisation gateway opened on 30 September 2026 and which goes live on 25 October 2027, they will need FCA authorisation, and the FCA expects them to apply by 28 February 2027. Cryptoassets

Custody and wallet providers

Safeguarding cryptoassets for customers is one of the activities the new regime brings in. Non-custodial wallet software raises different questions, depending on what control the provider has.

Stablecoins and tokenisation

Issuing a stablecoin in the UK is within the new regime. Tokenised securities or funds are usually treated as the underlying investment, so the existing rules for shares, bonds or funds apply.

Web3 projects and token sales

Whether a token is regulated depends on the rights it gives. Since 8 October 2023, promotions of qualifying cryptoassets to UK consumers have been within the financial promotion regime, even where the project itself is not authorised.

Insurance and warranties

Insurtech and embedded insurance

Introducing customers to an insurer or broker can be insurance distribution. Many businesses do it as an introducer appointed representative of an authorised firm, and a narrow exclusion covers some insurance sold alongside goods or services. Insurance introductions

Warranties, service plans and guarantees

Whether a warranty, service plan or guarantee is a contract of insurance depends on its terms, who carries the risk and whether the provider is also the seller or manufacturer. The FCA’s Perimeter Guidance manual sets out how it approaches the question.

Property

Estate and letting agents

Agents who refer clients for mortgages or insurance need to check whether they are only introducing or are arranging. Letting and property management work itself is generally outside the FCA perimeter.

Buy-to-let and landlord lending

Most buy-to-let lending to landlords running a business is outside the regulated mortgage rules. Consumer buy-to-let, where the landlord did not set out to be one, has its own FCA registration regime.

Property investment and development

Raising money from investors for developments, joint ventures or loan notes raises collective investment scheme and financial promotion questions. Property and investment schemes

Professional services

Accountants and solicitors

Some professional firms can carry on limited regulated activities that are incidental to their professional work under the rules of their professional body, without FCA authorisation. Activity that goes beyond that needs its own answer.

Consultants, corporate finance and M&A advisers

Advising on or arranging deals in shares, for example on the sale of a company, can be regulated. There is an exclusion for some sales of a body corporate, but its conditions are specific. Exclusions

Employee benefits and earned wage access

Earned wage access and salary advance products have had FCA attention. Whether they are regulated credit depends on how they are structured, who provides the money and what is charged.

Retail and consumer businesses

Retailers offering finance at checkout

Interest-free instalment products from a third-party lender have been regulated since 15 July 2026, and the rules include a specific exclusion for credit broking in relation to those agreements. Other point-of-sale finance usually makes the retailer a credit broker. Buy now pay later

Subscriptions and pay-monthly models

Spreading the cost of goods or services over time can be credit, and renting goods to consumers can be consumer hire. Some short-term arrangements are exempt, so the detail of the terms matters.

Car dealers and motor finance

Dealers that introduce customers to finance are usually credit brokers and need permission, often limited permission. Commission arrangements in motor finance have been the subject of court cases and FCA work.

Marketing, media and agencies

Marketing agencies running finance campaigns

Agencies that create or place adverts for financial products need to know whether the content is a financial promotion and who has approved it. Platforms such as Google and Meta also run their own verification for financial services advertisers. Google and Meta ads without an FCA number

Finfluencers, creators and affiliates

Posts about investments, credit or other regulated products can be financial promotions, and both the creator and the business paying them can be responsible. FCA guidance FG24/1 covers social media. Social media and affiliates

Publishers and content sites

Editorial content about financial products can sometimes rely on exemptions, but paid placements, affiliate links and calls to action can change the position.

Overseas firms

Firms entering the UK market

An overseas firm dealing with UK customers may be able to rely on the overseas persons exclusion for some activities, but its marketing into the UK is caught by section 21 if it can have an effect here. Overseas firms

Do not see your sector?

These are the most common, not the only ones. If your business touches money, credit, payments, investment, insurance or crypto in a way that is not listed, book a short call and we will tell you which questions apply.

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