Category: Compliance & AML · Reviewed by Mark Fox, Broker · Renewals · Last reviewed June 2026
An unauthorised firm or individual that carries on regulated activity under a written contract with — and the regulatory responsibility of — an authorised Principal, taking advantage of the section 39 FSMA exemption from the general prohibition.
An Appointed Representative (AR) is a person who, by virtue of FSMA section 39, can carry on regulated activities without being authorised because it does so under a written agreement with an authorised Principal. The Principal accepts full regulatory responsibility for the AR’s conduct in the activities covered by the agreement.
FSMA section 39. FCA Handbook, SUP 12. The FCA significantly tightened the regime through PS22/11 (December 2022) introducing enhanced oversight obligations on Principals.
A Principal must keep records of each AR, perform a fitness assessment before appointment, monitor the AR’s activity, ensure the AR is appropriately trained and supervised, and report at least annually on the AR’s activity (revenue from regulated activity, complaints, etc.). Principals must notify the FCA when appointing or terminating an AR. The AR may conduct the activities covered by the written agreement and within the Principal’s own permission. The AR cannot have its own Part 4A Permission for the same activity.
A “multi-principal” AR has more than one principal — permitted under section 39 with strict allocation rules. An Introducer Appointed Representative is limited to introducing potential customers. The PS22/11 enhancements include annual self-assessment, enhanced regulatory reporting, financial-controlled oversight, and tighter conflicts of interest provisions.
Apex is not an AR — it is an Authorised Person in its own right with FRN 724952. A firm operating as Apex’s AR would carry on Apex’s regulated insurance distribution activity under Apex’s brand and supervision, with Apex assuming regulatory responsibility for the AR’s conduct.
Financial Services and Markets Act 2000, section 39. FCA Handbook, SUP 12. FCA Policy Statement PS22/11 (Improvements to the Appointed Representatives regime).
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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