Last Updated on September 8, 2026
There is a sentence in the footer of a great many UK adviser websites that is, for some of those firms, factually untrue. It is checkable in about thirty seconds on a free public register, and it sits under a rule requiring communications to be fair, clear and not misleading.
What the FCA actually says
From the FCA’s own consumer pages, read on 8 September 2026:
| Point | FCA wording |
|---|---|
| Authorised | Being authorised means that firms must meet certain standards and have our permission to provide certain products and services |
| Appointed representative | ARs are carrying out activities on behalf of another firm, known as their principal |
| Who carries the risk | The principal agrees what activities the AR can do and is responsible for that business |
| The consumer warning | If an AR has gone beyond the activities the principal has allowed, you may not be protected by the Financial Ombudsman or the FSCS if something goes wrong |
| How to tell | Both appear on the Register with different designations, and consumers can ask the principal to confirm what the AR has permission for and how they would be protected |
That fourth row is the sharpest sentence in the whole of adviser marketing, and it comes from the regulator rather than from a competitor.
An appointed representative is not authorised in its own right. It operates under somebody else’s permissions. So a footer reading we are authorised and regulated by the Financial Conduct Authority, published by an AR, is describing a status the firm does not hold.
That is not a technicality in this sector. It is a financial promotion, and COBS 4.2.1R requires a communication or financial promotion to be fair, clear and not misleading, taking into account the nature of the client.
The correct construction names the principal. Something like: Smith Financial Planning Limited is an appointed representative of Principal Firm Limited, which is authorised and regulated by the Financial Conduct Authority, firm reference number 123456.
That is accurate, it is what the register says, and it takes ten minutes to fix.
This is the part most directly authorised firms miss. They have a genuine structural advantage and never mention it, because they assume clients understand the distinction. Clients do not.
The honest way to make the point is to describe the difference and let the reader draw the conclusion, rather than to attack ARs, many of which are excellent firms operating entirely properly:
We are directly authorised by the Financial Conduct Authority, firm reference number 123456, which means our permissions are our own rather than held through a principal firm. You can check what we are permitted to advise on, for free, on the FCA register.
Every clause there is verifiable. That is the whole point.
How a client checks, and how to teach them
Two free consumer tools, both from the FCA and both read on 8 September 2026: the Financial Services Register itself, and the FCA Firm Checker. The register is a public record of firms, individuals and other bodies that are, or have been, authorised by the FCA or PRA, and it shows whether firms are authorised or registered and what products and services they are allowed to offer.
The FCA also warns about clone firms, which it defines as a copy of a genuine, authorised firm, and directs consumers to its Warning List.
A short page on your site teaching a client to run those checks on anybody is genuinely useful, costs nothing, and quietly sets a standard. It also happens to be exactly the shape of content an AI assistant can use when somebody asks how to check a financial adviser.
The register check nobody is running
Whito published a check this morning on AI-recommended mortgage advisers against the FCA register. The broader pattern from our August 2026 work is worth knowing: of 32 mortgage firms ChatGPT gave a star rating across six UK cities, 28 had a perfect 5.0, and only 5 of the 71 firms named were recommended by all three AI engines.
Engines are already answering best financial adviser in a given city. Whether the firms they name are authorised in their own right, or are ARs, or are neither, is a question with a free public answer that nobody has published at scale. If your own status is precise and prominent, you are on the right side of that when it is published.
The regime around it, briefly
Two things worth having straight.
The Senior Managers and Certification Regime categorises solo-regulated firms as Limited Scope, Core or Enhanced. The Enhanced thresholds are assets under management of £65 billion or more on a three year rolling average, total intermediary regulated business revenue of £45 million or more, consumer credit lending revenue of £130 million or more, or 10,000 or more regulated mortgages outstanding for a non-bank lender or administrator. Practically every small advice firm is Core or Limited Scope.
The regime is also moving. PS26/6, published 22 April 2026, sets out phase 1 reforms across ten areas, with most changes effective 24 April 2026, reporting and process changes from 10 July 2026, Directory updates from 30 July 2026 and changes aligned with PS25/23 on non-financial misconduct from 1 September 2026. A second phase consultation is expected later in 2026.
Common questions
Can an appointed representative say it is FCA authorised?
No. An AR carries out activities on behalf of a principal, which holds the permissions and is responsible for that business. The accurate construction names the principal and its firm reference number.
Does it matter to a client?
The FCA thinks so. It warns consumers that if an AR has gone beyond the activities the principal has allowed, they may not be protected by the Financial Ombudsman or the FSCS if something goes wrong, and tells them to ask the principal what the AR is permitted to do.
How do I check a firm’s status?
On the FCA’s Financial Services Register, which is free and public, or through the FCA Firm Checker. Both show whether a firm is authorised or registered and what it is allowed to offer.
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