The question
Can you earn commission for referring UK businesses to a lender or credit broker without being FCA authorised? For most activities, yes — within clear limits.
This guide explains what you can and cannot do, and the cleanest way to earn referral commission without becoming a regulated firm.
The regulated activity: credit broking
The FCA regulates “credit broking” as an activity. Credit broking — broadly — means introducing customers to lenders or credit brokers in the course of a business, in circumstances where the customer would reasonably expect to be matched to a credit product.
If you are doing this regularly and for commercial gain, you are likely carrying on a regulated activity. That requires FCA authorisation (or Appointed Representative status under an authorised firm).
What does not require FCA authorisation
Simple introductions — telling someone about a broker or lender, sharing a link, mentioning that funding options exist — are generally considered outside the regulated perimeter, provided you:
- Do not advise the customer on which credit product is appropriate
- Do not assist the customer in completing an application
- Do not compare or recommend specific lenders
- Do not hold yourself out as a credit broker
An affiliate who places a banner link on their website, includes a sponsored mention in their newsletter, or refers a contact verbally to a broker is, in most cases, not carrying on regulated credit broking activity.
The affiliate programme model
The affiliate programme model is specifically structured to keep activity within the non-regulated perimeter:
- You register with a broker (like Fundably)
- You receive a unique tracking link
- You share that link — on your website, in content, via email, or directly
- Businesses apply via your link
- The broker handles the entire application and lending process
- You earn commission based on funded deals
Your role is distribution. The regulated activity — credit broking, application processing, lender matching — is handled entirely by the authorised broker.
Fundably is FCA authorised and NACFB registered. Affiliate partners do not need their own FCA authorisation.
The grey areas
Some activities push closer to regulated territory:
Personalised recommendations: saying “you should use Fundably specifically because your credit profile is X” — this could be construed as advice. Better: “here is a link to Fundably, who match businesses to 50+ lenders.”
Application assistance: helping a client complete the Fundably application is borderline. Better to let the broker’s team handle this.
Repeat professional introducing: if a business consultant regularly introduces clients to lenders as a core service, the FCA may consider this a regulated activity even if the introducer does not complete applications. Professional introducers at significant scale should take their own advice.
Practical steps
- Apply to Fundably’s affiliate programme — takes 24–48 hours to set up
- Get your unique tracking link
- Share it in the ways that suit your audience
- Earn commission when your referrals are funded
If you are uncertain about the regulatory position for your specific situation, take advice from an FCA compliance specialist or contact the FCA’s firm helpline (0300 500 0597).
This guide does not constitute legal or regulatory advice.