FCA Publishes Review on Inactive Appointed Representatives
The FCA wants firms to clean up their Appointed Representative registers — inactive ARs are a compliance risk.
What Changed
On April 21, 2026, the FCA published its review of good practice and areas for improvement in firms' supervisory work relating to inactive Appointed Representatives. The FCA identified firms that maintained AR registrations for entities that had ceased operating, never commenced activity, or had not conducted regulated business for extended periods. The regulator expects principal firms to actively manage their AR registers and terminate relationships with inactive ARs.
Who It Affects
Any FCA-authorized firm that uses the Appointed Representative model — including payment institutions, electronic money institutions, and investment firms. The review signals that the FCA will take enforcement action against principal firms that fail to oversee their ARs.
What to Do
Audit your AR register. Identify any ARs that are inactive, have ceased trading, or are not conducting regulated activity. Terminate relationships with non-operational ARs and update the FCA register. Implement ongoing monitoring of AR activity to prevent future accumulation of inactive relationships.
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