Credit Intermediary Compliance Checklist

Establish the intermediary perimeter

List the actual services performed at every step of a credit application. A merchant may display finance promotions, a comparison website may rank lenders, and a specialist broker may gather information or help conclude the agreement. The correct regulatory classification depends on what happens rather than the trading name. Record the creditor, consumer, intermediary, credit product, country, remuneration and contractual relationships. UK article 36A of the Regulated Activities Order includes specified credit broking activities, subject to applicable exclusions. Do not presume a retailer qualifies for limited permission simply because arranging finance is secondary to selling goods. Where several entities participate, document the responsibility of each one.

Verify permissions and jurisdictions

Check whether each credit-broking activity requires FCA authorisation, an appointed representative relationship or another lawful basis in the United Kingdom. Verify the exact permissions, business model, exemption conditions and any restrictions before publication of offers. A firm authorised for one regulated service should not imply it may undertake unrelated financial activities. For EU business, distinguish current national law from Directive (EU) 2023/2225 measures generally applying from 20 November 2026. Member State implementation and transitional provisions determine the practical requirements. A UK authorisation is not a substitute for assessing another country's laws. Maintain evidence of legal review and update it when new lender partnerships or products are introduced.

Review promotions and broker status

Check every material consumer-facing channel including advertisements, mobile landing pages, store quotations, comparison results and email referrals. Identify the creditor and intermediary accurately and explain the broker's role when required. FCA CONC 3 includes financial promotion provisions, including broker status requirements in relevant cases. Consumers should not be told the intermediary searches the entire market when it operates only a restricted lender panel. Avoid guaranteed approval or preapproved claims without an appropriate basis. Verify any representative examples or rate claims against the actual credit offers and applicable rules. Retain screenshots and version numbers so reviewers can reconstruct the information shown at the customer's decision point.

Evaluate charges and commissions

Differentiate fees charged directly to consumers from commission or incentives paid by lenders. UK CONC 4.4 contains customer fee requirements in applicable circumstances, while CONC 4.5 addresses remuneration disclosure where relevant conditions are met. Review whether the existence or amount of a commission could affect impartiality or materially influence a consumer's transactional decision. A generic statement that a firm may be paid is not necessarily enough for all arrangements. Test commission tiers, sponsored rankings and sales incentives, including motor finance and merchant checkout journeys. Confirm when a consumer receives relevant information and how it can be retrieved later. Keep records of fee agreements, deductions, refunds and remuneration policies.

Protect customer information and outcomes

A broker's application process may collect employment, income, contact and financial information. Map who obtains the data, which lenders or affiliates receive it, the purpose of each transfer and the lawful processing grounds. Privacy information should reflect actual recipients and activities. Provide a practical route for customers to dispute inaccurate application details, complain about unexpected contacts or request accessible communications. Do not promise acceptance before the creditor has made its credit decision. Test how failed applications, merchant returns and cancelled financing are handled across multiple systems. Define who resolves complaints and who ensures that corrections reach all relevant participants. Preserve proportionate evidence without retaining personal information indefinitely.

Maintain records and supervisory controls

Create an audit trail for intermediary classification, approval of promotional materials, lender-panel decisions, fees, disclosures and application handoffs. A currently correct webpage does not establish what consumers saw under earlier terms. Version digital screens and sales scripts, and preserve records that support individual complaints and internal testing. Assess applicable FCA and data protection retention requirements rather than inventing a universal retention period. Evaluate outsourced affiliates and lead suppliers through samples of actual communications, not only contractual warranties. Check that sales incentives, compliance escalation and third-party responsibilities are clearly assigned. Record control failures, affected customers, owners of remediation and evidence that corrective measures worked.

Test and refresh the full checklist

Audit at least one simple referral, a multi-lender comparison, a retail point-of-sale purchase, a commission-funded recommendation and a customer-paid broking service where offered. For each, verify the jurisdiction, legal status, marketing claims, lender identity, fee disclosures, data journey and complaint route. Review edge cases such as withdrawn offers, rejected credit and consumer allegations of misleading commission information. Confirm that generated guide pages have the correct canonical URL, indexable robots metadata and sitemap inclusion. These publishing controls do not themselves prove legal compliance, but they protect access to educational materials. Revisit the checklist after changes to national implementing laws, FCA guidance, products or commercial arrangements.

Frequently asked questions

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