Empowering Financial Services: The Strategic Alliance of Principals and Appointed Representatives

In the dynamic landscape of financial services, the role of Appointed Representatives (“ARs”) has been pivotal in extending the reach of regulated activities without the need for direct authorisation. However, with great power comes great responsibility and the Financial Conduct Authority (“FCA”) has taken significant steps to ensure that this delegation of duties does not compromise consumer protection or market integrity.

An AR is a firm or person who carries out regulated activities under the supervision and responsibility of an authorised firm, known as the “Principal Firm”. The Principal Firm is tasked with ensuring that the AR is fit for purpose, financially stable and compliant with FCA rules.

Key Changes

Principal Firms are now expected to:

  1. Provide detailed information about their ARs, enhancing transparency;
  2. Ensure ARs are fit and proper before appointment and throughout their tenure;
  3. Regularly review AR activities and report any significant changes to the FCA;
  4. Maintain adequate resources to oversee ARs effectively; and
  5. Adhere to new reporting requirements, including annual complaints data and revenue information for ARs.

Implications for Principals and ARs

The updated guidelines necessitate a strategic approach from Principals, namely:

  • Implementing robust oversight frameworks for ARs
  • Conducting annual risk assessments and self-reporting to ensure compliance
  • Utilising Management Information (MI) systems to meet reporting requirements

For ARs, this means operating within a more structured and monitored environment, (i.e., complying with the same regulatory standards as their Principal, receiving adequate training to understand these regulations and being regularly monitored to ensure compliance) ensuring their activities align with the Principal’s regulatory obligations.

Strategic Considerations for Principals

With the updated regime, Principals must re-evaluate their strategies concerning ARs. The heightened regulatory expectations may lead to increased compliance costs and necessitate a thorough review of existing AR relationships. Principals should consider the following:

  • Foster a culture of compliance and transparency
  • Engage in continuous professional development to stay abreast of regulatory changes
  • Leverage technology to streamline oversight and reporting processes


The FCA’s revamped AR regime presents both challenges and opportunities. For Principal Firms, it is a chance to reinforce their commitment to market integrity and consumer protection. For ARs, it is an invitation to align with the highest standards of conduct. Together, Principals and ARs can navigate the enhanced regulatory landscape, ensuring the financial services industry remains robust, trustworthy, and consumer centric.

How Can Complyport Help?

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About Complyport

Complyport is a market-leading consulting firm supporting the UK financial services industry for over 22 years. We specialise in providing Governance, Risk and Compliance services to support the regulated financial services industry to raise standards and thrive.

Complyport can assist with the preparation of a GAP analysis and impact assessment on the investment firm’s capital adequacy and risk management framework of the Company under the regulatory framework.

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