Is introducing clients regulated in the UK?
Usually, yes. Under the UK's regulated activities rules, "making arrangements with a view to transactions in investments" covers many introductions to brokers, including introductions to forex and CFD providers. Doing it by way of business without authorisation, or without an exemption, can be a criminal offence. Whether a specific setup is caught depends on the facts, so take advice from a UK regulatory lawyer before you start.
Three ways to operate as a UK introducer
| Route | What it means | Typical fit |
|---|---|---|
| Your own FCA authorisation | You apply to the FCA for the permissions you need and meet its rules directly. | Larger IB businesses that want independence. |
| Appointed representative (AR) | An authorised "principal" firm takes regulatory responsibility for your activities under a written contract. | Businesses that need wider permissions under a principal. |
| Introducer appointed representative (IAR) | A restricted AR who can only introduce clients and distribute certain non-real-time promotions approved by the principal. | Most individual IBs and creators who only refer clients. |
ARs and IARs appear on the FCA register under their principal firm. If a broker invites you to be its introducer, ask how it will appoint you and when you'll appear on the register.
Financial promotion rules
Under section 21 of the Financial Services and Markets Act 2000, only an authorised person may communicate an invitation or inducement to engage in investment activity, unless an authorised firm approves the promotion or an exemption applies. Since February 2024, authorised firms need specific FCA permission to approve promotions made by unauthorised people. In practice:
- Social posts, videos and ads that encourage people to open a trading account are usually financial promotions.
- If you're not authorised, your promotions generally need approval from an authorised firm, often the broker you work with.
- Promotions must be fair, clear and not misleading, and include the required risk warnings.
CFD and forex marketing restrictions
The FCA's permanent rules for retail CFDs (including rolling spot forex) limit leverage, for example 30:1 on major currency pairs, require a standardised risk warning showing the percentage of the firm's retail accounts that lose money, and ban most trading bonuses and incentives for retail clients. As an introducer you must not promise profits, offer bonuses the broker can't legally give, or hide the risk warning.
Finfluencers and the FCA
The FCA has published guidance on financial promotions on social media and has brought criminal cases against people who promoted unauthorised investments online. If you create content as an introducer, treat every post that links to a broker as a regulated promotion: get it approved, show the risk warning prominently, and keep records.
Checklist before you become a UK introducer
- Confirm the broker is FCA-authorised on the FCA register, not just a clone with a similar name.
- Agree in writing how you will be appointed (AR or IAR) and who approves your promotions.
- Read the introducer agreement: commission model, clawbacks, data protection and termination. Our IB agreement checklist helps.
- Prepare compliant content: risk warnings, no return claims, no unapproved incentives. See forex IB marketing rules.
- Register with HMRC for tax on your commission income and keep good records.
This guide is general information, not legal advice. UK rules change; check the FCA Handbook and current guidance.
Frequently asked questions
Do I need FCA authorisation to be an introducing broker in the UK?
Usually you need either your own authorisation or an appointment as an appointed representative or introducer appointed representative of an FCA-authorised firm. Operating without either can be a criminal offence.
What is an introducer appointed representative?
An IAR is a person appointed by an FCA-authorised firm who can only introduce clients to it and distribute certain approved non-real-time promotions. The principal firm is responsible for the IAR's regulated activities.
Can I promote an offshore broker to UK residents?
Promoting firms that are not authorised to serve UK retail clients is likely to breach the financial promotion rules. Check the FCA register before you promote any broker.
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