HM Treasury published a policy statement on the United Kingdom’s Appointed Representatives (AR) regime, confirming it intends to preserve the regime’s current broad scope while making targeted legislative reforms to strengthen principal oversight and consumer redress. The government plans to consult on the detailed design of the reforms in due course. The statement outlines two intended changes. First, authorised firms would need to obtain permission from the Financial Conduct Authority (FCA) before appointing ARs, creating a regulatory gateway aimed at ensuring principals have the expertise, resources and systems to oversee AR activity, with the FCA able to apply limitations, conditions, variations or withdrawal. This reform would likely require amending section 39 of the Financial Services and Markets Act 2000 and therefore primary legislation, and the government indicates it is working with the FCA on an approach intended not to disrupt existing principal firms, including by not requiring them to apply for the new permission and embedding the permission into the new firm authorisation process. Second, the government intends a targeted extension of the Financial Ombudsman Service (FOS) compulsory jurisdiction so that where a complaint involves an AR and the FOS finds the principal is not responsible for the issue in dispute, the FOS could investigate the AR directly and, if upheld, direct redress to the AR. Next steps centre on developing and consulting on detailed proposals for both reforms, with the principal permission dependent on securing a place in the legislative programme. The extension of FOS jurisdiction is to be designed and implemented consistently with the government’s published conclusions from its review of the FOS.
HM Treasury 2025-08-11
United Kingdom's HM Treasury sets out plans to retain the Appointed Representatives regime while adding FCA permissioning for principals and extending Ombudsman coverage
HM Treasury's policy statement on the UK's Appointed Representatives regime confirms plans to maintain its broad scope while reforming principal oversight and consumer redress. Key changes include requiring authorised firms to obtain Financial Conduct Authority permission before appointing ARs and extending the Financial Ombudsman Service's jurisdiction for direct AR investigations. The government will consult on the detailed design of these reforms.