Do accountants need FCA authorisation to refer clients for lending?
No, most UK accountants do not need FCA authorisation to refer clients for lending. The key reason is that commercial credit broking to UK Limited companies sits outside the FCA regulated perimeter. Where your clients are Ltd-company SMEs going through a commercial finance broker like Fundably, you are not carrying on regulated activity, regardless of volume. Even where a client is in the consumer-credit space (sole traders, individuals), the introducer model below keeps you outside the regulated activity.
What the FCA says
The FCA regulates “credit broking” as an activity, but the perimeter is narrower than many accountants assume. The two key carve-outs are:
- Borrower type: regulated credit broking captures introductions involving consumer credit and individual or sole-trader borrowing. Introducing UK Limited companies (and most partnerships of more than three persons) for commercial finance is not a regulated activity under UK law.
- Activity type: even within the consumer-credit perimeter, the FCA distinguishes regulated credit broking (advising on or arranging specific credit products) from simple introductions (pointing a customer in the direction of a regulated firm without advice).
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 accountants whose clients are predominantly UK Ltd-company SMEs.
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.
Professional bodies including ICAEW and ACCA generally confirm that members acting as introducers for lending products, where the referral is incidental to their accountancy services and the client is a Ltd-company SME, do not need separate FCA authorisation.
The safe path: use a regulated broker
The cleanest approach for most accountants is:
- Partner with a commercial finance broker that is an NACFB member (like Fundably, with access to 50+ UK lenders including iwoca, Funding Circle, Nucleus Commercial Finance and Capital on Tap)
- 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. Fundably’s partner programme offers accountants up to 30% commission per funded deal across a panel of 50+ lenders. For a step-by-step look at how the commission model works, see our guide on how accountants earn commission on lending referrals.
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. If you want to explore this route further, our guide on adding funding advisory to your accountancy practice covers how to build this into your services.
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 |
Frequently asked questions
Do accountants need FCA authorisation to refer clients to iwoca or Funding Circle?
No. Referring Ltd-company clients to a commercial finance broker like Fundably, which accesses lenders including iwoca, Funding Circle, Nucleus Commercial Finance and Capital on Tap, does not require your firm to hold FCA authorisation. Commercial credit broking to UK Limited companies sits outside the FCA regulated perimeter, and the broker handles the regulated activity in any case.What is the difference between introducing and credit broking?
An introduction means sharing a link, referral or contact, then handing off entirely to the broker. Credit broking means advising on specific products, comparing lender offers or helping complete applications. The former is generally outside the FCA regulatory perimeter; the latter requires authorisation.Can I be penalised by ICAEW or ACCA for referring clients to lenders?
No, provided you disclose the arrangement to your client and are not advising on specific credit products. Both ICAEW and ACCA have confirmed that earning referral commission as an introducer is permissible for members. Check your professional body's guidance if uncertain.What should I do if a client asks which loan to take?
Direct them to the broker. If a client asks you to compare options from iwoca versus Funding Circle, or to recommend a specific deal, that is credit broking and may require FCA authorisation. The clean answer: "That's a question for the broker. They'll be able to compare the options properly for you."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.