HomeGuides › Home improvement

Do home improvement companies need an FCA licence to offer finance?

By Peter ZacUpdated 4 June 20268 min read

Finance closes home-improvement sales — kitchens, windows, conservatories, solar and the rest are exactly the kind of high-value purchase customers like to spread out. But arranging that finance brings your business under FCA regulation, and there's a wrinkle specific to your trade: selling in the customer's home changes the rules. This guide explains when a home-improvement company needs FCA authorisation, which type, the in-home selling point you must know, and what it costs.

The short answer

Yes. If your business arranges finance for customers, or simply introduces them to a lender, you must be authorised by the Financial Conduct Authority (FCA) — or operate under someone else's authorisation as an "appointed representative." That's true even though a separate finance company does the actual lending. The only home-improvement firms that fall outside it are those that sell strictly for cash and never discuss, arrange, or refer finance at all.

You'll often hear this called a "consumer credit licence." Strictly there's no licence any more — what you need today is FCA authorisation (also called "permission") — but the everyday term is fine, and we use it too. For the full picture across all industries, see our step-by-step guide to getting an FCA consumer credit licence. This article focuses on what it means for home-improvement companies.

Why offering finance makes your business "regulated"

Here's the part that catches a lot of installers out: you don't have to lend any of your own money to be regulated. When you help a customer spread the cost of a new kitchen, windows, a conservatory or solar panels, you're almost always introducing them to a finance provider that does the lending. That act of introducing customers to a lender is called credit broking, and credit broking is itself a regulated activity under FCA rules.

It makes no difference if the finance is interest-free to the customer. In most "buy now, pay later" or "0% finance" deals in this trade, the installer subsidises the interest — but you're still introducing the customer to a lender, so you still need authorisation. The precise rule on when interest-free credit is exempt — and when it isn't — is in our guide to 0% finance and FCA authorisation.

The in-home selling twist you must know about

There's a rule specific to your trade that's easy to miss. If you offer to sell your goods or services during a visit to a customer's home — which is exactly how most kitchens, windows, conservatories and solar are sold — the FCA treats you as a "domestic premises supplier." A quote given in the customer's living room is enough to count. Solar and battery storage is the clearest case of all, since a system is almost always surveyed and quoted at the property — we cover that trade specifically in our guide for solar installers.

Why it matters: the lighter-touch introducer appointed representative (IAR) route that some businesses use is generally not available to domestic premises suppliers. In practice that means in-home sellers usually need their own credit broking authorisation (or full appointed-representative status under a principal) rather than the simplest introducer arrangement. So if you sell in customers' homes, don't assume a casual "introducer" set-up will cover you — it most likely won't.

Which permission do home-improvement firms need?

FCA authorisation comes in two tiers — limited permission and full permission — and for most installers the answer is limited permission.

The reasoning is straightforward. Your main business is supplying and installing improvements; finance is something you offer to help customers buy them. Because the credit broking is secondary to your main trade, the FCA treats you as a "supplier," and suppliers can apply for the lighter, cheaper limited permission tier. The permission you need is limited permission credit broking.

When a firm needs full permission instead

You'd move into full permission territory only if finance became a core activity in its own right — for example if arranging finance became a main part of what you do, if you brokered finance unconnected to your own work, or if you lent your own money so customers repaid you directly. Full permission carries heavier requirements, higher fees, and closer FCA scrutiny.

A simple rule of thumb: if you'd still have a business without offering finance, you almost certainly need limited permission, not full. If finance is the business, expect full permission.

The appointed representative route — with a caveat

You can offer finance under someone else's authorisation by becoming an appointed representative (AR) of an already-authorised firm — usually a finance provider or compliance network acting as your "principal." The principal takes legal responsibility for your compliance and the FCA deals with them rather than you. But remember the in-home selling point above: because you're likely a domestic premises supplier, the lightest "introducer" version of this route is generally closed to you, so the realistic choice is usually full AR status under a principal or your own direct authorisation.

The trade-offs are the familiar ones. As an AR you operate under someone else's permissions and rules, you're usually tied to their lender panel, you'll often pay an ongoing fee, and the principal can set conditions or end the arrangement. Direct authorisation means you hold your own permission on the FCA register, you choose which lenders to work with, you pay no network fee, and you're not dependent on anyone else to keep you on — in exchange for carrying your own compliance responsibilities.

Direct authorisation or AR — which is right for you?

It depends on how you want to run the business. AR status can suit a very small or brand-new firm happy to work within one principal's panel with minimal regulatory involvement. Direct limited permission tends to suit installers who want independence: their own authorisation, freedom to work with any lender, no ongoing network fee, and full control of their finance proposition. Many firms start as an AR and move to direct authorisation as they grow. If you'd rather own your authorisation than rent it, direct limited permission is the route — and it's more achievable than most installers expect.

What else you'll need to get right

Authorisation is the gateway, not the whole job. However you're authorised, you'll need to follow the FCA's consumer credit rules (its "CONC" sourcebook), advertise finance fairly under the financial promotions rules, check that customers can afford the repayments, disclose any commission clearly, handle complaints properly, and meet the FCA's Consumer Duty — the requirement to deliver good outcomes for customers, including those who are vulnerable. Because you often sell in the customer's home, you'll also need to respect cancellation rights that apply to in-home sales. These are ongoing obligations, and they apply proportionately to a small limited permission firm.

What you need to apply

For a direct limited permission application, you'll typically prepare a regulatory business plan, your compliance arrangements, a set of key policies (financial promotions, complaints handling, treating vulnerable customers fairly, and anti-money laundering), basic financial information, and details of an approved person the FCA will assess as "fit and proper." The application is submitted through the FCA's online portal, Connect. We walk through the full document list and the process in our guide to getting authorised. If you'd rather have it prepared for you, our fixed-price service for home-improvement firms does exactly that.

What it costs and how long it takes

There are two separate costs to budget for:

  • The FCA's application fee — currently around £560 for a limited permission credit broking firm, paid to the FCA when the application is submitted. The FCA sets and occasionally changes its fees, so check the current figure on its website.
  • Preparing the application — you can do it yourself, pay a compliance consultancy (often £2,000 or more), or use a fixed-price service. This is where the cost varies most.

There's also a small annual fee to the FCA once you're authorised. On timing, the decision is the FCA's and it does not commit to a date. Incomplete applications are the main cause of delay: the FCA's assessment does not begin in earnest until it has everything it has asked for.

What happens if you offer finance without authorisation

This isn't a grey area worth gambling on. Arranging or introducing finance without being authorised — and without operating as an appointed representative — is a criminal offence. It can also make your credit agreements unenforceable, which creates real problems if you ever need to rely on them, and it exposes the business to FCA enforcement and reputational damage. If there's any doubt about whether you need authorisation, confirm your position before you start offering finance.

Frequently asked questions

Does the in-home selling rule really mean I can't be an introducer appointed representative?

Generally yes. As a “domestic premises supplier” — a firm that offers to sell during visits to customers' homes — the lightest introducer route is usually not available, so you'll typically need your own credit broking permission or full AR status. It's worth confirming your exact position before relying on a simple introducer arrangement.

We only offer interest-free finance and subsidise the interest — do we still need authorisation?

Yes. Whether the customer pays interest or you subsidise it, you're still introducing them to a lender, which is regulated credit broking. The authorisation requirement is the same.

Is limited permission enough?

For most installers, yes. Because supplying and installing improvements is your main business and finance is secondary, the FCA treats you as a “supplier” who can apply for limited permission. Full permission only applies if finance became a core activity or you funded the lending yourself.

Which trades does this cover?

Any home-improvement business that offers finance — kitchens and bathrooms, windows and doors, conservatories and orangeries, solar and battery storage, roofing, driveways and landscaping, and more. See our guidance for home-improvement firms for how the service works.

This article is general information to help you understand the process, and is not legal or regulatory advice. CreditLicence is a regulatory consultancy; it is not authorised or regulated by the Financial Conduct Authority, nothing it provides is regulated advice, and it is not affiliated with, endorsed by, or acting on behalf of the FCA. FCA fees and rules can change; always check the FCA's website for the current position.

Begin an Application

A short form to begin. A member of our team will call the same business day to discuss your firm's activities and the application.

Begin an Application
£995fixed fee. The FCA's £560 application fee is separate and itemised
3business days to a completed pack, once we have your details
17documents in every application, tailor-made for your firm