Introducer Appointed Representative (IAR)

Category: Compliance & AML · Reviewed by Simon Temme, Account Executive · Last reviewed June 2026

A narrow form of Appointed Representative whose activity is limited to effecting introductions of potential customers to authorised firms (and ARs of authorised firms) and distributing non-real-time financial promotions on behalf of the Principal.

Definition

An Introducer Appointed Representative (IAR) is a sub-species of AR whose activities are strictly limited. An IAR can introduce potential customers to its Principal (or other persons connected with the Principal) and can distribute non-real-time financial promotions prepared and approved by the Principal. An IAR cannot give advice, conclude a contract on the customer’s behalf, or carry on any regulated activity beyond introduction.

Legal / Regulatory basis

FSMA section 39 (the AR exemption) combined with FCA Handbook SUP 12.2.7G and SUP 12 Annex 1 (the IAR scope). Article 33 of the Regulated Activities Order (S.I. 2001/544) addresses the introducing activity.

How it works in practice

The Principal enters into a written agreement specifying the IAR’s permitted introduction activity. The Principal maintains responsibility for the conduct of the introduction activity and for any promotion materials. The IAR cannot recommend, advise, or arrange — its role is limited. The Principal must perform fitness checks and ongoing monitoring as with any AR, but the scope is narrower.

Common variations

Some commercial introducers are IARs of a single Principal; others are unregulated lead-generators outside the AR regime. The line between introducing (lawful for an IAR) and arranging (which requires permission) is important — see PERG 5.7 for the FCA’s guidance.

Example

A property letting agent that wishes to send its landlord clients a flyer about a Principal’s landlord insurance product, and to forward potential customer details to the Principal, could be appointed as an IAR of an authorised insurance intermediary — taking care that any conversation with the customer remains an introduction and not advice.

See also

• Appointed Representative (AR)
• Authorised Person
• Permitted activities
• ICOBS 5 — Identifying client needs and advising

References

FCA Handbook, SUP 12.2.7G, SUP 12 Annex 1. Financial Services and Markets Act 2000, section 39. Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (S.I. 2001/544), article 33. FCA Handbook, PERG 5.7.

Last reviewed

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.