How to Refer Businesses for Loans Without an FCA Licence

Can you refer businesses for loans without an FCA licence?

Yes, you can refer UK businesses for business loans and earn commission without an FCA licence. Crucially, commercial credit broking to UK Limited companies sits outside the FCA regulated perimeter, so referring Ltd-company funding does not require your own authorisation. Affiliate partners referring business loans through Fundably, an NACFB member commercial finance broker whose panel includes iwoca, Funding Circle, Nucleus Commercial Finance and Capital on Tap, do not need their own authorisation because the broking activity is handled entirely by Fundably.

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, but the perimeter is narrower than many people assume. Credit broking is broadly defined as introducing borrowers to lenders or other brokers in the course of a business.

The key carve-out for business referrals: credit broking to UK Limited companies (and to most partnerships of more than three persons) is not a regulated activity under UK law. Regulated credit broking only captures introductions involving consumer credit and individual / sole-trader borrowing. If your referrals are exclusively to Ltd-company SMEs going through Fundably, you are outside the FCA perimeter regardless of volume.

If you also refer sole traders, individual landlords or other consumer-credit applicants, that activity is regulated and would require FCA authorisation (or Appointed Representative status under an authorised firm).

What does not require FCA authorisation

Simple introductions, such as telling someone about a broker or lender, sharing a link or 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. For accountants and bookkeepers specifically, see our guide on FCA authorisation rules for accountants.

The affiliate programme model

The affiliate programme model is specifically structured to keep activity within the non-regulated perimeter:

1. You register with a broker (like Fundably)
2. You receive a unique tracking link
3. You share that link on your website, in content, via email or directly
4. Businesses apply via your link
5. The broker handles the entire application and lending process
6. 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 an NACFB member commercial finance broker. Affiliate partners do not need their own FCA authorisation when referring UK Ltd-company funding.

The grey areas

Some activities push closer to regulated territory:

Personalised recommendations: saying “you should use Fundably specifically because your credit profile is X” 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 position depends on whether the borrowers are Ltd companies (outside the FCA perimeter) or include consumer-credit applicants (inside the perimeter). Professional introducers operating at scale, or referring a mix of Ltd and individual borrowers, should take their own advice. Bookkeepers and accountants in this position should also read our guide on how accountants earn lending commission.

Practical steps

1. Apply to Fundably’s affiliate programme, which takes 24–48 hours to set up
2. Get your unique tracking link
3. Share it in the ways that suit your audience
4. 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.

Ready to start earning referral commission? Apply to Fundably’s affiliate programme. Setup takes 24-48 hours, there are no fees, and Fundably handles all the regulated activity on your behalf.

Frequently asked questions

Can a sole trader or individual (not a business) refer loan applications and earn commission?

Yes. Individual affiliates, sole traders and content site operators can all earn referral commission without FCA authorisation, provided they limit their activity to distribution (sharing a link or mentioning the broker) and do not advise on specific products or assist with applications.

Is there a limit on how many referrals I can make before I need FCA authorisation?

For referrals exclusively to UK Limited companies through a commercial finance broker like Fundably, there is no volume threshold that triggers FCA authorisation, because the activity sits outside the FCA perimeter. The position changes if you also refer sole traders, individual landlords or other consumer-credit applicants, where regulated credit broking rules apply. When in doubt, take specialist compliance advice.

What commission can I earn from Fundably's affiliate programme?

Fundably pays up to 30% of the commission Fundably receives from the lender on each funded deal. The average commission paid out per funded deal is around £2,000, with smaller deals at £100 to £500 and larger deals (£250k+) paying £5,000 to £10,000+. Commission is paid within 14 days of the deal funding.

Do I need to register with Fundably to use the referral link?

Yes. You need to apply to the affiliate programme (free, 24–48 hours to set up) to receive your unique tracking link. This ensures referrals are attributed to you and you receive commission payments.