Appointed representatives and tied agents

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This Overview is a guide to the Financial Services content within the Appointed representatives and tied agents subtopic, with links to the appropriate materials.

In line with section 19 of the Financial Services and Markets Act 2000 (FSMA 2000), a person cannot carry out a regulated activity in the UK, or purport to do so, unless they are either authorised by the Financial Conduct Authority (FCA) or the Prudential Conduct Authority (PRA) or are an exempt person in relation to that activity. This is called the general prohibition. Persons who are not authorised by the FCA or PRA and who carry out regulated activities on behalf of authorised persons will be exempt from the general prohibition as 'appointed representatives' (ARs) if they meet the requirements of FSMA 2000, s 39. Authorised persons with a limited permission to carry out certain credit activities will also qualify as ARs where they act on behalf of other authorised persons to carry out regulated activities outside of their limited permission if they meet the requirements of FSMA 2000, s 39(1D). Although they won't be exempt persons,

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Latest Financial Services News

Financial Services—other developments (11/7/2025)

A round-up of other developments, which have not been covered in full by the LexisNexis Financial Services practical guidance team but may nevertheless be of interest.

Commission adopts ‘quick fix’ amendments to European Sustainability Reporting Standards

The European Commission has adopted a Delegated Regulation amending Delegated Regulation (EU) 2023/2772 which sets out the European Sustainability Reporting Standards (ESRS). The ESRS specify the information which companies must disclose against pursuant to their sustainability reporting obligations under the EU Corporate Sustainability Reporting Directive (CSRD). The proposed ‘quick fix’ amendments are designed to reduce the reporting burden on companies already reporting pursuant to the CSRD for the 2024 financial year (so called ‘wave one’ companies). Pursuant to the ‘Stop the Clock’ Directive adopted as part of the sustainability omnibus package of February 2025, wave two and three companies have seen their reporting obligations delayed by two years. Wave one companies were not captured by this change, hence today’s proposal. Preparations are underway for a broader revision of the ESRS framework as part of the sustainability omnibus package of reforms (which includes sweeping changes to the CSRD).

BIS outlines regulatory challenges and policy approaches for stablecoin growth

The Bank for International Settlements (BIS) has published a bulletin analysing regulatory challenges posed by stablecoins' growing integration with traditional finance. The report notes stablecoin market capitalisation has reached US$255bn today, up from US$125bn in 2023. The BIS has identified key policy challenges including anti-money laundering compliance, monetary sovereignty risks and financial stability concerns. The bulletin concludes that while ‘same risks, same regulation’ principles have limitations for stablecoins, regulatory frameworks should combine traditional financial oversight with tailored approaches addressing stablecoins' specific features, particularly at interfaces with regulated financial systems.

PSR publishes 2024/25 annual report and 2025/26 work programme

The Payment Systems Regulator (PSR) has published its Annual Report and Accounts for 2024/25, outlining progress made at the midpoint of its five-year strategy. The report highlights the implementation of the authorised push payment (APP) scams reimbursement requirement, which has resulted in a high reimbursement rate for victims, and the expansion of Confirmation of Payee to cover the majority of Faster Payments transactions. It also details work on card fee reviews, collaboration with the Financial Conduct Authority (FCA) on open banking, and preparations for the PSR’s planned consolidation into the FCA. These developments are presented in the context of the PSR’s strategic focus on competition, innovation and consumer protection.

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