Understanding UK consumer credit regulation
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How to comply with FCA credit broking requirements. Covers who counts as a credit broker, the difference between full and limited permission, exemptions that may apply, initial disclosure obligations, fee transparency, and commission disclosure rules.
Check if your business introduces customers to credit products like loans or Buy Now Pay Later. If you do, you probably need FCA authorisation as a credit broker. Apply for full or limited permission based on your activities. Some exemptions apply, like offers of interest-free credit repayable in 12 months or fewer.
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If your business introduces consumers to a credit product, you are likely acting as a credit broker and need FCA authorisation. Many retailers, motor dealers, and service providers do not realise they are carrying on credit broking activity.
You are a credit broker if you:
Operating as a credit broker without FCA permission is a criminal offence. Any credit agreements arranged through an unauthorised broker may be unenforceable.
For credit broking, the distinction between full and limited permission depends on the nature of your activity:
| Full permission | Limited permission |
|---|---|
| You actively sell or recommend credit products | You simply introduce customers to a lender |
| You compare or advise on credit options | You present a single lender's products at point of sale |
| Credit broking is a core part of your business model | Credit broking is ancillary to your main business |
| Higher application fee | Lower application fee |
| More extensive application requirements | Simplified application |
Most retailers and motor dealers offering finance through a single provider will qualify for limited permission. If you offer finance from multiple lenders or actively compare products for customers, you are likely to need full permission.
Check carefully whether an exemption applies before relying on one. The most commonly used exemptions are:
BNPL merchants: The 12-month interest-free exemption does not apply to merchants introducing customers to a third-party BNPL provider. From 15 July 2026, if you offer BNPL at checkout through a third-party provider, you will need credit broking permission.
Review all the ways your business helps customers access credit. This includes point-of-sale finance, referrals to lenders, BNPL integrations, and any arrangement where you introduce consumers to a credit product. If you are unsure, check the FCA's Perimeter Guidance Manual (PERG) Chapter 17.
Determine whether your activity falls within a recognised exemption. If you rely on the 12-month interest-free exemption, verify that the credit is provided by you (not a third-party lender), carries no interest or charges, and is repayable in 12 or fewer instalments. Document your exemption analysis.
If no exemption applies, apply for consumer credit permission via FCA Connect. Choose limited permission if your broking activity is ancillary to your main business and you work with a single lender. Choose full permission if you compare products or actively sell credit. Application fees range from GBP 280 (limited) to GBP 5,000 (full).
Before doing anything that amounts to credit broking, you must tell the customer that you are acting as a credit broker, not a lender. State the name of the lender or lenders whose products you offer. This disclosure should be in writing or other durable medium.
If you charge customers a fee for arranging credit, disclose the fee amount before providing your service. The GBP 250 fee cap applies to secondary credit brokers. You must also disclose commission arrangements on request, and proactively under the Consumer Duty where commission could influence your recommendation.
Staff involved in credit broking must understand the products they are offering, the disclosure requirements, and when to refer customers to the lender for further information. Maintain records of disclosures made, complaints received, and any fees charged.
If your business offers Buy Now Pay Later at checkout through a third-party provider such as Klarna, Clearpay, or Laybuy, you will need FCA credit broking permission from 15 July 2026. This applies whether you are an online retailer, a bricks-and-mortar shop, or a service provider.
Most BNPL merchants will qualify for limited permission. Start preparing now:
See Buy Now Pay Later regulation: what businesses need to know for the full picture of BNPL regulation.
Authoritative sources on credit broking requirements.
FCA Consumer Credit sourcebook chapter on credit broking conduct requirements.
fca.org.ukFCA Perimeter Guidance on what constitutes credit broking activity.
fca.org.ukFCA overview of consumer credit permission types and application process.
fca.org.ukStep-by-step guidance on the FCA authorisation application.
fca.org.ukDefines regulated credit broking activities.
legislationPrimary consumer credit legislation.
legislation