What an Appointed Representative (AR) Can and Cannot Do

An Appointed Representative (AR) plays a key role in the UK financial services sector, particularly in industries such as automotive retail and insurance. Operating under the oversight of a Principal firm authorised by the Financial Conduct Authority (FCA), ARs can carry out regulated activities — but only within the scope of the permissions their Principal holds.

Understanding what an Appointed Representative can do and cannot do is essential for firms to stay compliant, avoid regulatory risk, and ensure customers receive fair outcomes.

What an Appointed Representative Can Do

Unlike an Introducer Appointed Representative (IAR), an AR has a far broader role and can engage in regulated activities on behalf of their Principal.

1. Market and Sell Financial Products

An AR can promote, explain, and sell financial and insurance products to customers, provided these activities are covered by their Principal’s FCA permissions.

2. Handle Customer Information

ARs are permitted to collect, process, and store customer details during the sales process. This includes gathering information for finance applications, insurance policies, or other regulated services.

3. Manage the Full Customer Relationship

An Appointed Representative may deal with the entire customer journey, including:

• Customer service enquiries

• Policy renewals

• Cancellations and amendments

• Handling claims or complaints

4. Operate as an Extension of the Principal

In effect, the AR acts as a regulated extension of the Principal’s business. They can perform most of the activities that a directly authorised firm could, but always under the Principal’s supervision.

What an Appointed Representative Cannot Do

Despite their wider scope, ARs are not completely unrestricted. An AR must remain within the permissions granted by their Principal. They cannot:

• Carry out regulated activities outside the scope of the Principal’s FCA permissions

• Operate independently without a contract and oversight from a Principal

• Approve their own financial promotions — only the Principal can approve and sign off on marketing materials

• Avoid FCA oversight — ARs remain under regulatory scrutiny through their Principal’s responsibilities

AR vs IAR: The Key Difference

The difference between an AR and an IAR comes down to scope and responsibility:

• An IAR can only introduce customers and share pre-approved promotions.

• An AR can sell products, advise customers, and manage the full lifecycle of customer relationships.

For many businesses, becoming an AR provides greater flexibility and control compared to being an IAR — but it also carries greater responsibility and compliance obligations.

Why These Distinctions Matter

Clearly defining the role of an AR helps businesses to:

• Stay compliant – Avoid carrying out unauthorised activities outside FCA permissions

• Protect customers – Ensure customers receive accurate information and fair treatment

• Reduce risk – Prevent fines, enforcement action, and reputational damage

Compliance Support with ComplianceTrak

At ComplianceTrak, we help dealer groups and financial services firms manage their Appointed Representative and Introducer Appointed Representative networks with confidence. Our compliance software and expert team ensure businesses remain aligned with FCA requirements while delivering a seamless customer journey.

Contact the ComplianceTrak team today to learn how we can support your compliance framework.