Do you need FCA authorisation to broker commercial finance?
For unregulated commercial finance brokered to limited companies, you do not need FCA authorisation. The line is set by borrower type and product: broking to sole traders, partnerships, or individuals, and regulated products such as residential mortgages, consumer credit, or Start Up Loans to individuals, can require FCA permission. Get the structure right from day one.
Most aspiring commercial finance brokers get stuck on this question before they have written a single deal. The answer is not complicated, but it turns on who you are lending to and what product you are placing, and getting it wrong is a criminal matter, not just a compliance inconvenience.
For the core commercial market, broking unregulated commercial finance to limited companies falls outside the FCA's regulated-activities regime entirely, with no authorisation and no appointed-representative arrangement required. We operate in this space and have done deals from day one of trading. The boundary is sharp rather than fuzzy, so this page sets out exactly where it falls. Nothing here is legal advice; if your plans touch the edges, get your own regulatory opinion before you trade.
The core rule: the limited company is the key
The Financial Services and Markets Act 2000 and the Regulated Activities Order 2001 define what needs FCA authorisation. The structural point for commercial brokers is this: arranging finance for a limited company for its business purposes generally falls outside the consumer-credit regulated activities. A limited company is not an individual. The consumer protections that trigger FCA regulation are aimed at individuals, and a limited company does not qualify.
In practice, a broker whose clients are UK-registered limited companies, placing unsecured business loans, invoice finance, asset finance, bridging, or commercial mortgages, can place deals and earn commission without any FCA permission. We work this way. It is a well-established, legitimate structure in the UK commercial market, not a loophole.
Where the line is drawn: sole traders, partnerships, and individuals
The limited-company exemption does not extend to every business borrower. Sole traders are individuals in the eyes of the law, whatever they call their business. Under Article 36A(4) of the Regulated Activities Order, arranging a credit agreement can be a regulated activity where the borrower is an individual or a small partnership acting for business purposes, even for a loan that would otherwise be an exempt business agreement.
That distinction trips people up. A sole trader applying for a working capital loan is still an individual; arranging that finance can require FCA permission depending on the product, the amount, and how it is structured. Before you take on sole-trader or partnership clients, take specific regulatory advice on your exact product set. We focus on limited-company borrowers precisely to keep that boundary clean.
Regulated products always require FCA permission
Borrower type aside, some products are regulated regardless of who is borrowing. These include:
- Residential mortgages (first and second charge), including any lending secured on a borrower's own home - Consumer credit products such as personal loans, hire purchase to individuals, and credit cards - Start Up Loans up to £25,000 made to individuals, which are personal loans backed by the British Business Bank and are regulated consumer credit
None of those can be introduced or arranged without the appropriate FCA permission or a valid appointed-representative arrangement with an authorised firm. If a client asks about a Start Up Loan, the compliant response is to point them to the British Business Bank or an FCA-authorised firm. We do not arrange these products, and our panel does not cover them.
What about CeMAP or other qualifications?
CeMAP is a qualification for residential mortgage advisers. It is not required for commercial finance broking. Holding it does not give you any additional permissions for commercial products, and the absence of it costs you nothing in the unregulated commercial space.
There is no equivalent mandatory qualification for unregulated commercial finance broking in the UK. Lenders assess your competence differently: the quality of your submissions, your grasp of their credit criteria, your ability to package a deal cleanly. That is what matters on our panel. Our training is built around what lenders actually expect, not a course designed for a different market.
Do you need to register with anyone?
For unregulated commercial finance broking to limited companies, you do not appear on the FCA Register, hold an FCA reference number, or notify the FCA of your business. That is the point.
Separately, you will need to register with HMRC for anti-money-laundering supervision under the Money Laundering Regulations 2017 where that applies to your activity. That is a different and much simpler process than FCA authorisation. It does not stop you trading while the registration is in progress, but you should not delay it. Keep clean AML records from day one regardless, because the obligations sit on you as a business even before you have formally registered.
Frequently asked questions
If I only broker to limited companies, do I need any FCA involvement at all?
No. For unregulated commercial finance placed with UK-registered limited companies (business loans, invoice finance, asset finance, bridging, commercial mortgages), you do not need FCA authorisation, an appointed-representative arrangement, or any FCA permission. You trade as an ordinary limited company under standard company law. If you later add regulated products or take on individual, sole-trader, or partnership borrowers, that changes immediately, so keep your activities inside the unregulated space unless you resolve your regulatory status first.
Can I broker to sole traders without FCA authorisation?
Not straightforwardly. Sole traders are individuals under the Regulated Activities Order, and Article 36A(4) can bring some business-loan arrangements within the regulated perimeter even for products that would otherwise be exempt. Before accepting sole-trader or partnership clients, take specific regulatory advice on the products you intend to place and how they are structured. We focus on limited-company borrowers to keep that line clear.
Are Start Up Loans something I can broker?
No. Start Up Loans of up to £25,000 made to individuals are regulated consumer credit products administered via the British Business Bank. Introducing or arranging them without FCA authorisation is not permitted. Refer those enquiries to the British Business Bank or an FCA-authorised firm. Our panel covers unregulated commercial products for limited companies, not Start Up Loans.
What about commercial mortgages on investment or trading property?
Commercial mortgages on commercial property held in a limited company (offices, industrial units, retail premises) are generally unregulated for limited-company borrowers. Residential mortgages, and any second-charge lending secured on a borrower's own home, are regulated regardless of the stated purpose. If you are unsure whether a specific security type is regulated, treat it as regulated until a legal or compliance adviser confirms otherwise.
Do I need to register with the FCA at all, even if I am not authorised?
Not for unregulated commercial finance broking. You do not need to appear on the FCA Register or hold an FCA reference number. You do need to register with HMRC for anti-money-laundering supervision under the Money Laundering Regulations 2017 where that applies to your activity. That is a separate, much simpler process, and the two are often confused.
Start broking on the right foundations
No franchise fee (competitors charge roughly £6,000 to £30,000). No FCA application for unregulated commercial finance to limited companies. A specialist lender panel, deal CRM, document handling, and commission splits from 55% on your first funded deal. If you want to start with the regulatory picture clear, talk to us.
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