Principal & AR Oversight
Appointed representative oversight for principal firms, covering due diligence, onboarding, monitoring, annual reviews, notifications and remediation.
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What We Do
A principal firm is regulatorily responsible for the regulated activities of its appointed representatives as if it had carried them out itself. That responsibility does not scale automatically, and the FCA has been explicit that oversight in many principal firms has not kept pace with the growth of AR networks.
The reforms introduced through PS22/11 raised expectations significantly on pre-appointment due diligence, ongoing monitoring, annual self-assessment and the information principals must provide to the FCA. Firms that treated AR appointment as a commercial onboarding process are the ones now under supervisory pressure.
We build and test AR oversight frameworks that are proportionate to the risk each AR presents, and we remediate networks where monitoring has been nominal, financial promotions have gone unchecked or the AR has drifted outside the scope of its appointment.
Framework Review
We assess current oversight arrangements against principal firm obligations and the enhanced expectations.
Due Diligence & Onboarding
We design proportionate pre-appointment due diligence and scope of appointment controls.
Monitoring Programme
We build risk-based monitoring, file testing and financial promotions oversight across the AR population.
Annual Review & Reporting
We implement the annual self-assessment, board reporting and regulatory notification processes.
What's Included
AR Oversight Framework
End-to-end framework from due diligence through to termination, sized to the network.
Pre-Appointment Due Diligence Pack
Assessment criteria covering solvency, fitness, competence, business model and expected regulated activity.
Scope of Appointment Controls
Clear definition of permitted activities with controls that detect activity outside scope.
Risk-Based Monitoring Programme
Tiered monitoring, file testing, promotions review and thematic assessment across the population.
Annual Self-Assessment
The annual review of adequacy of controls and resources, structured for board consideration.
Notification & Remediation Support
Regulatory notifications, AR termination and remediation where oversight has failed.
Who This Service Is For
Firm Types
- - Insurance principal firms and networks
- - Mortgage networks
- - Consumer credit principals
- - Investment and wealth principal firms
Situations & Triggers
- - The AR population has grown faster than the oversight function
- - Monitoring is inconsistent or largely unevidenced
- - An AR has operated outside its scope of appointment
- - The FCA has requested information about AR arrangements
Why Work With Us
Financial Services Only
We operate exclusively within regulated financial services. Every member of our team has direct regulatory experience in this sector.
Senior-Led Delivery
Every engagement is led by a senior consultant with hands-on regulatory experience - not delegated to junior staff.
Practical, Not Theoretical
We build frameworks that work in practice, not just on paper. Our advice is grounded in what regulators actually expect.
Global Reach
We advise across 65+ jurisdictions, combining local regulatory knowledge with a consistent, high-quality approach.
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Frequently Asked Questions
A principal is responsible for the regulated activities its appointed representatives carry on under the appointment, as though the principal had carried them on itself. That includes the AR's conduct with customers, its financial promotions and its compliance with applicable rules within the scope of appointment.
The FCA strengthened expectations on pre-appointment due diligence, ongoing monitoring proportionate to risk, an annual self-assessment of the adequacy of the principal's controls and resources, enhanced notification requirements before appointment and additional annual reporting on AR activity and revenue.
Financial position and solvency, fitness and propriety of individuals, competence and capability to carry on the proposed activities, the business model and how the AR will generate revenue, expected regulated and unregulated activity, any regulatory history, and whether the principal has sufficient resources to oversee the appointment.
Frequency should be risk-based. Higher risk ARs, judged by activity type, customer base, complaint history, growth rate and previous findings, require more frequent and deeper testing. A single uniform annual visit across an entire network is rarely defensible.
A documented review of whether the principal's systems, controls and resources remain adequate for the AR population it oversees. It should be considered by the governing body and should reach a genuine conclusion, including where the principal needs to invest further or reduce the network.
Yes. We scope the exposure across the population, prioritise by risk, rebuild the monitoring framework, run catch-up testing, support notifications and terminations where required and put in place management information that keeps oversight visible to the board.