Whatever kind of intermediary you are — a broker, an adviser, a dealer, a fund manager or an administrator — the same regulated-firm duties form your baseline. Put these in place, then follow the guide for your specific activity. Everything in this guide applies UK-wide.
Hold the right permissions
Most intermediary activities — advising, arranging, dealing as agent, managing investments, insurance distribution — are regulated activities under the Regulated Activities Order: you need FCA Part 4A permission for each one you carry on, or — where available — an exemption such as appointed representative status. Check the perimeter with do I need FCA authorisation, weigh appointed representative against direct authorisation, and apply via apply for FCA authorisation — you will need to meet the threshold conditions on an ongoing basis.
Operate the SM&CR
As a solo-regulated firm you sit in the SM&CR's limited scope, core or enhanced tier depending on your size and activities: senior managers need FCA approval, certification staff are assessed annually, and conduct rules apply to almost everyone.
Deliver the Consumer Duty
If retail customers sit anywhere in your distribution chain, the Consumer Duty (Principle 12) applies: fair value, communications that support understanding, and monitoring of customer outcomes.
For implementation detail, see FCA Consumer Duty compliance requirements.
Keep promotions compliant
Everything you publish to win business is potentially a financial promotion under section 21 FSMA — it must be fair, clear and not misleading, and approving promotions for unauthorised persons has its own gateway.
Handle complaints under DISP
Complaints from eligible complainants follow the FCA's Dispute Resolution sourcebook, with referral rights to the Financial Ombudsman Service.
Run anti-money-laundering controls
Financial intermediaries are squarely in scope of the Money Laundering Regulations: risk assessments, customer due diligence, monitoring and reporting, with the FCA supervising most authorised firms.
Meet operational resilience requirements
In-scope firms must identify their important business services, set impact tolerances for disruption and be able to stay within them. See also cyber security for financial services firms.
Protect personal data and pay the ICO fee
Client financial data is core personal data — handle it under the UK GDPR, and unless exempt register with the ICO and pay the annual data protection fee.
If you administer occupational pension schemes
Pension scheme administration is regulated by The Pensions Regulator, not the FCA — these duties apply even if you hold no FCA permission. As an administrator acting for trustees you support the scheme's TPR obligations: registrable information and scheme returns, record-keeping and data quality, and connection to pensions dashboards. Alongside these, the industry's administrator competence standards — Pensions Management Institute qualifications and PASA accreditation — are the recognised, though non-statutory, benchmark.
The trustees' own duties — funding, knowledge and understanding, the scheme-side dashboards obligations — are in run an occupational pension scheme.
Next steps
With the shared duties in place, follow the guide for your activity:
- Insurance distribution and loss adjusting rules
- Financial adviser and intermediary rules
- Investment firm and trading venue rules
- Fund and asset management rules
Then confirm everything with the financial intermediary compliance checklist.
Legal basis
Primary legislation and key regulations