What an Introducer Appointed Representative (IAR) Can and Cannot Do
- Sep 23, 2025
- 2 min read
Updated: Nov 5, 2025
Understanding the Role of an IAR
When working with Introducer Appointed Representatives (IARs), it’s vital to understand the strict limits of their role under Financial Conduct Authority (FCA) regulations. Many firms confuse IARs with Appointed Representatives (ARs), but the two operate very differently. Misunderstanding these distinctions can lead to serious compliance risks and potential FCA enforcement action.
What an Introducer Appointed Representative Can Do
An IAR’s role is very narrow. Their activities are limited to two main areas:
1. Make Introductions
An IAR can collect a potential customer’s details and pass them to their Principal firm (usually a broker, lender, or group company). Their responsibility is simply to introduce the customer.
They cannot advise, recommend, or complete any transactions. Doing so may be classed as carrying out unauthorised regulated activity.
2. Distribute Approved Financial Promotions
An IAR may share FCA-compliant financial promotions created and approved by the Principal. However, they cannot create or amend these materials themselves. Their role is limited to distribution only.
In short: an IAR can open the door to a conversation but cannot guide the customer through the process.
What an Introducer Appointed Representative Cannot Do
To stay compliant, IARs must avoid crossing into regulated activity. An IAR cannot:
Advise or recommend financial products
Negotiate terms or complete transactions
Handle payments or process claims
Provide aftersales support or maintain an ongoing customer relationship
Any of the above would fall outside the IAR’s scope and create significant regulatory risks.
How IARs Differ from ARs
An Appointed Representative (AR) operates under broader permissions granted by their Principal and can effectively act as an extension of the Principal’s business. Unlike IARs, ARs can:
Obtain and process customer information
Market and sell financial products
Handle customer service, cancellations, claims, and renewals
Manage the full end-to-end customer journey
In many ways, being an AR mirrors the responsibilities of being directly authorised by the FCA, provided the Principal has the correct permissions.
Why These Distinctions Matter
Clearly defining the boundaries between IARs and ARs is crucial for:
Regulatory Compliance – Preventing unauthorised activity and avoiding FCA penalties
Operational Clarity – Ensuring staff, partners, and introducers understand exactly what their role allows
Compliance Support with ComplianceTrak
At ComplianceTrak, we support dealer groups and financial services businesses in managing their FCA compliance responsibilities with clarity and confidence.
If you’re unsure whether your business should work with IARs or ARs, contact the ComplianceTrak team today for expert guidance.