The short answer
Most UK accountants can refer clients to a regulated credit broker and earn commission without their own FCA authorisation — provided they stay within the boundaries of an introductory role.
What the FCA says
Business lending falls under the FCA’s consumer credit regulatory framework, governed by the Consumer Credit Act and the Financial Services and Markets Act. Within this framework, “credit broking” is a regulated activity.
However, the FCA’s guidance distinguishes between:
- Regulated credit broking — introducing customers to lenders or brokers in return for a fee, with the expectation of doing so as part of a business
- Simple introductions — pointing a customer in the direction of a regulated firm without providing any form of advice or assistance with the credit decision
The FCA’s guidance states that a person is not carrying on a regulated activity if they merely communicate information about credit products without recommending a specific product or lender.
The practical implication: sharing a partner link, submitting a referral form, or saying “you should speak to Fundably about your funding options” does not constitute regulated credit broking for most accountants.
What requires FCA authorisation
You need FCA credit broking authorisation if you:
- Introduce customers to credit brokers or lenders as a primary business activity
- Provide advice on which specific credit products a customer should consider
- Complete or assist with filling in loan application forms on a customer’s behalf
- Assess a customer’s creditworthiness or suitability for specific products
- Receive commission that is contingent on the customer taking specific credit (at scale)
The distinction between “introducing” and “advising/arranging” matters. Most accountants who refer funding needs pass quickly to a broker and do not advise on products — this is an introduction, not broking.
The accountant exemption
ICAEW and ACCA members who are exempt by their professional body under the Financial Services and Markets Act 2000 (Appointed Representative) may have additional protections. Check with your professional body if you are uncertain.
The ICAEW Business Finance Guide (updated 2024) confirms that members acting as introducers for lending products — where the referral is incidental to their accountancy services — generally do not need separate FCA authorisation.
The safe path: use a regulated broker
The cleanest approach for most accountants is:
- Partner with an NACFB-authorised credit broker (like Fundably — NACFB authorised, NACFB member, ICO ZB024107)
- Refer via a partner portal or link — the broker then contacts the client directly
- Do not advise on products — if a client asks which loan to take, direct them to the broker
This keeps your activity within straightforward introduction territory and puts the regulated activity on the broker, where it belongs.
What if I want FCA authorisation?
Some accountants — particularly those building a dedicated funding advisory service or white-label funding practice — choose to seek their own FCA authorisation for credit broking. This allows them to manage the full application process, compare specific products, and potentially earn higher fees.
This is a multi-month process requiring:
- A Firm Application to the FCA
- Demonstration of competent persons and procedures
- Professional indemnity insurance covering credit activities
- Compliance framework and policies
For most accountants, this is disproportionate to the activity level. The introducer model achieves the commercial outcome (commission on funded deals) without the regulatory overhead.
Summary
| Activity | FCA authorisation required? |
|---|---|
| Sharing a partner referral link | No |
| Submitting a referral via broker portal | No |
| Telling a client “speak to Fundably” | No |
| Advising on which loan product to take | Yes |
| Comparing specific lender offers for a client | Yes |
| Completing loan applications on behalf of clients | Yes |
When in doubt, contact the FCA’s firm helpline or your professional body for specific guidance on your situation. This guide does not constitute legal advice.