Introducer Appointed Representatives: what they can and can't do

An Introducer Appointed Representative can do two things: effect introductions, and distribute financial promotions approved by their Principal. Anything beyond that risks carrying out regulated activity without authorisation. An IAR is not the same as a full Appointed Representative, and treating the two as interchangeable creates compliance risk for both the IAR and the Principal.

The regime for Appointed Representatives is set out in the FCA’s SUP 12 (opens handbook.fca.org.uk in a new tab) sourcebook.

What an IAR can do

The role is narrow and focused.

Effect introductions

An IAR can collect a potential customer’s contact details and pass them to the Principal - usually a broker or lender - or to a firm within that group. The job is to introduce, not to advise, sell or complete a transaction.

Going beyond this, by recommending products or negotiating terms, could be unauthorised regulated activity and expose both the IAR and the Principal to enforcement action.

Distribute financial promotions

An IAR may share approved marketing material created by and branded as the Principal. They cannot create or alter financial promotions themselves - only share content already approved for use.

In short: an IAR can open the door to a conversation, but cannot walk the customer through it.

What an IAR cannot do

• Advise customers, or explain product details in a way that could be a recommendation
• Negotiate terms or handle any part of the transaction
• Collect payments or process claims
• Maintain an ongoing customer relationship on behalf of the Principal

How this differs from a full AR

An Appointed Representative can do considerably more, provided the Principal holds the relevant FCA permissions and has permitted it contractually. In effect the AR operates as an extension of the Principal’s business, under its permissions and supervision.

An AR can:

• Obtain and process customer details
• Market and sell products directly to customers
• Handle customer service issues, claims, cancellations and renewals
• Maintain the full end-to-end customer relationship

Why the distinction matters

Compliance risk. An IAR overstepping its authority could be conducting unauthorised regulated activity, with enforcement consequences for both parties.

Operational clarity. Internal teams and partners need to know exactly who can do what. Most breaches here are not deliberate - they happen because someone helpful answered a question they were not permitted to answer.

Our Appointed Representatives service covers both Principal and AR obligations in more detail.