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Glossary

Appointed Representative (AR)

An Appointed Representative is a company, partnership or sole trader that carries on certain regulated activities without being authorised, because an authorised firm, its principal, has accepted responsibility for that business in writing. The AR is an exempt person under section 39 of FSMA, but only for the business its principal has accepted. What the AR does in that business is treated as the principal's own act.

The conditions

  • The AR is not itself authorised, has a written contract with an authorised principal for business of a kind the Appointed Representatives Regulations allow, and the principal has accepted responsibility in writing (SUP 12.2.2G).
  • A firm cannot be exempt for some regulated activities and authorised for others, except a firm with only a limited permission (SUP 12.2.3G).
  • The business an AR may be exempt for is limited to the list in the Regulations. In consumer credit that includes credit broking, debt adjusting, debt counselling, debt collecting, debt administration and consumer hire. Regulated claims management cannot be carried on as an AR (SUP 12.2.7G).

What the principal takes on

  • The principal is responsible for the AR's acts and omissions in that business as if it had expressly permitted them (SUP 12.3.2G, section 39(3) FSMA).
  • An AR may not hold client money, except under the insurance intermediary provisions in CASS 5.5 (SUP 12.6.5R).
  • A firm with five or more ARs, not counting IARs, or fewer ARs with 26 or more representatives between them, is a network (SUP 12.2.6G).

Common misconceptions

“An AR is FCA authorised.”
It is exempt, not authorised. In April 2026 the FCA cited an AR website calling itself “FCA authorised” as misleading, and said ARs should not call themselves “Authorised Representatives” either.
“The AR is responsible for its own compliance.”
The contract must require the AR to comply (SUP 12.5.5R), but regulatory responsibility sits with the principal (SUP 12.3).

In Merrin

Merrin keeps each AR's record, people, agreement, returns and reviews in one place, from onboarding to termination.

AR onboarding

Sources

Checked against these sources on . This is general information, not legal advice.

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