Per our recent post, the FCA has now published its plans for the coming year.  There are perhaps no surprises to see that the Appointed Representative (AR) regime remains an area of focus for the regulator this year, as it was last year.   See also, for example, our previous posts here, here, here, here and here, amongst others

In the 24/25 Business Plan, the FCA reminds principal firms of the same points it made in the 23/24 Business Plan; namely that:

  • principal firms are responsible for ensuring their ARs comply with FCA rules;
  • the FCA however still sees many principals failing to adequately oversee their ARs’ activities; 
  • consumers are at risk of being misled and mis-sold;
  • misconduct by ARs in the financial sector can undermine market integrity;
  • new rules and guidance came into effect on 8 December 2022 aiming to improve principals' oversight of their ARs, increase the information they give the FCA and raise standards across financial services. 

For 24/25, the FCA plans to continue:

  • to target its resources through deeper analysis of existing data and using significantly improved data, including from updated gateway forms, new regulatory returns and a dataset covering all ARs;
  • to strengthen its scrutiny and engagement with principal firms as they appoint ARs;
  • its assertive supervision of high-risk principals, through our regulatory tools and appropriate enforcement action.

The proper oversight of ARs by principal firms therefore appears to remain a key area of concern for the FCA.  As we've noted previously, principal firms should accordingly ensure they have properly adjusted to the new regime and stay alert for further developments.