8. June 2026
FCA Appointed Representatives Data Publication: Implications for Principal Firms, Appointed Representatives and Regulatory Hosting Businesses
Regulatory Briefing Note No. 04/26 - June 2026
Audience: Principal Firms, Appointed Representatives (‘ARs’), Regulatory Hosting Firms, Insurance Intermediaries, Consumer Credit Firms and Compliance Professionals
Executive Summary
The Financial Conduct Authority (‘FCA’) has published its latest Appointed Representatives (‘AR’) data, providing an updated view of the size, composition and economic activity of the AR regime https://www.fca.org.uk/data/appointed-representatives-data
The publication highlights a continuing reduction in the number of principal firms and ARs operating within the regime, whilst simultaneously reporting significant growth in revenues generated through AR activities [1] .
At March 2026, the FCA reported:
- 2,431 principal firms
- 33,347 active ARs
- 20,728 Full ARs
- 12,619 Introducer ARs (‘IARs’)
Although the overall AR population reduced by 0.7% over the previous year, regulated financial services revenue generated by ARs increased to approximately £13.1 billion during 2025, representing growth of 7.3%.
The FCA states that the data supports its objective of becoming a more data-led regulator and assists in identifying emerging risks, directing supervisory resources and assessing the effectiveness of principal oversight arrangements.
The publication provides a clear indication that supervisory attention is increasingly focused on the quality of governance, oversight and risk management within AR networks rather than simply the size of those networks.
The FCA's Supervisory Message
The latest publication reinforces the FCA's continued focus on strengthening oversight of the AR regime.
The regulator highlights the role of data collected through:
- REP025 submissions
- Add, Change and Terminate AR notifications
- Retail Mediation Activities Returns (‘RMAR’)
- Other regulatory reporting mechanisms
The FCA confirms that it uses this information to:
- identify higher-risk principals;
- monitor emerging sector trends;
- assess AR business models;
- analyse revenue concentrations; and
- prioritise supervisory interventions.
A consistent theme throughout the publication is the regulator's increasing reliance on data-driven supervision and evidence-based decision making.
The FCA's message is clear: principal firms should be capable of demonstrating effective oversight through management information, governance reporting and risk monitoring rather than relying solely on documented policies and procedures.
Key Market Trends
Several notable trends emerge from the FCA's latest dataset.
Continued Consolidation
The number of principal firms has fallen by approximately 5.3% over the past year.
This continues a longer-term trend of consolidation within the AR market, likely reflecting:
- increased regulatory expectations;
- rising compliance costs;
- enhanced oversight obligations; and
- greater scrutiny of principal business models.
Revenue Growth Despite Fewer Firms
Whilst the overall AR population has reduced slightly, regulated revenue generated by ARs increased significantly.
This suggests:
- greater concentration of activity;
- larger AR networks generating higher revenues;
- increasing economic significance of the regime; and
- potentially greater systemic importance of principal firms.
Consumer Finance Growth
Consumer finance remains the largest AR sector by population and continues to grow.
The sector recorded the largest annual increase in AR numbers and generated approximately £3.3 billion in regulated revenue during 2025.
This may reinforce existing FCA concerns regarding:
- Customer outcomes.
- Affordability.
- Governance arrangements.
- Consumer Duty compliance.
Declining General Insurance Population
General insurance and protection continues to experience a reduction in AR numbers.
However, despite this decline, the sector remains the largest contributor to regulated revenue within the AR regime, generating approximately £4 billion during 2025.
Implications for Principal Firms
The FCA's publication is likely to increase expectations regarding principal oversight arrangements.
Principal firms may be expected to demonstrate:
- effective onboarding and due diligence processes;
- ongoing monitoring of AR activities;
- risk-based supervision frameworks;
- meaningful management information;
- complaint and customer outcome monitoring;
- Consumer Duty oversight; and
- robust governance structures.
The regulator's emphasis on revenue data suggests increasing focus on whether principal firms fully understand the scale and nature of activities conducted by their ARs.
Where significant revenue is generated through AR relationships, firms should expect greater supervisory scrutiny regarding the effectiveness of oversight arrangements.
Implications for Appointed Representatives
ARs should recognise that the FCA is increasingly using regulatory data to assess risks across the wider regime.
Although supervisory engagement is generally directed through principal firms, ARs may face increasing expectations regarding:
- data quality;
- reporting accuracy;
- governance arrangements;
- customer outcomes;
- complaint management; and
- financial resilience.
ARs operating within larger networks may also experience greater oversight from principals seeking to evidence compliance with FCA expectations.
Implications for Regulatory Hosting Firms
The publication is particularly relevant for regulatory hosting and network businesses.
The combination of:
- increasing revenue concentration;
- declining principal numbers; and
- enhanced FCA scrutiny
suggests that hosting firms may face greater regulatory expectations regarding governance and operational controls.
Areas likely to attract supervisory attention include:
- onboarding standards;
- oversight methodologies;
- AR risk assessments;
- thematic reviews;
- management information;
- board reporting; and
- Consumer Duty monitoring.
The FCA's increasing use of REP025 data may also enable supervisors to benchmark hosting firms against peers and identify outlier business models more readily than in previous years.
Governance and Senior Management Accountability
The publication reinforces broader regulatory themes around governance and accountability.
Senior Managers responsible for AR oversight are likely to be expected to demonstrate:
- effective challenge;
- oversight of network growth;
- understanding of revenue sources;
- monitoring of customer outcomes;
- risk escalation procedures; and
- evidence-based decision making.
As the FCA becomes increasingly data-led, firms should expect supervisory discussions to focus on objective evidence rather than narrative explanations.
Practical Considerations for Firms
In light of the FCA's findings, firms may wish to review:
- AR oversight frameworks;
- REP025 reporting processes;
- management information and KPI reporting;
- Consumer Duty monitoring arrangements;
- complaint analysis and trend reporting;
- governance committee structures;
- onboarding and due diligence procedures; and
- revenue concentration risks.
Firms should also consider whether existing oversight arrangements remain proportionate to the scale and complexity of their AR population.
Regulatory Outlook
The FCA's latest AR publication provides further evidence of an increasingly sophisticated and data-driven supervisory approach.
The regulator appears focused on:
- strengthening principal accountability;
- identifying emerging risks through data analysis;
- improving oversight of AR activities;
- monitoring revenue concentration; and
- ensuring firms can evidence effective governance.
The overall direction of travel suggests that regulatory expectations will continue to increase, particularly for principal firms operating larger or more complex AR networks.
Whilst the AR population continues to contract, the regime remains economically significant and strategically important within UK financial services. Firms should therefore expect AR oversight, governance and Consumer Duty outcomes to remain areas of active supervisory focus throughout 2026 and beyond.
[1] Key Sources: FCA: Appointed Representatives Data (5 June 2026); FCA: Improving the Appointed Representatives Regime Through Greater Use of Data; and FCA REP025 Reporting Framework.
The small print...
This document has been prepared by AJG Regulatory Solutions for the purpose of contributing to regulatory discussion and consultation. The views expressed in this response represent the professional opinions of AJG Reg Solutions based on our regulatory expertise and experience supporting firms operating in the financial services sector.
Unless explicitly stated otherwise, the views set out in this document do not represent the views of any individual client of AJG Reg Solutions. Any examples or references to market practice are provided for illustrative purposes only and should not be interpreted as referring to any specific firm.
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