“Credit broking” is the piece of jargon at the heart of consumer credit regulation — and the activity thousands of businesses carry out every day without realising it has a name, let alone that it's regulated. If you've ever helped a customer pay for something over time, this is the term that decides whether you need FCA authorisation. Here's what it actually means.
The short definition
Credit broking is, in essence, introducing a customer to someone who will lend them money — or helping to arrange that finance — in connection with buying goods or services. It's a regulated activity under FCA rules, which means that if you do it by way of business, you generally need to be authorised by the Financial Conduct Authority (FCA) or to act as an "appointed representative" of a firm that is. The key thing to grasp: you don't have to lend any of your own money to be a credit broker. The introduction itself is the regulated activity.
What the FCA actually counts as credit broking
The legal definition (set out in article 36A of the Regulated Activities Order) is broader than most people expect. In practice it covers:
- Effecting an introduction of a customer who wants credit to a lender, or to another credit broker;
- Presenting or offering a credit agreement to a customer;
- Assisting a customer by carrying out preparatory work towards a credit agreement;
- Entering into a credit agreement on a lender's behalf.
For the vast majority of shops, garages and practices, it's the first limb that bites — simply introducing customers to a lender so they can pay over time. That's why so many ordinary businesses are credit brokers without thinking of themselves as anything to do with financial services.
Everyday activities that count
You're almost certainly carrying out credit broking if you do any of these by way of business:
- Let a customer pay in instalments through a finance provider;
- Offer "0% finance" or interest-free credit arranged through a lender;
- Have a finance application form, or an "apply for finance" button, at the point of sale;
- Recommend or refer customers to a particular lender or broker;
- Arrange hire purchase or PCP on a vehicle.
Doing it only occasionally doesn't get you off the hook — if it's part of how you do business, it counts.
What doesn't count — but check carefully
A few situations fall outside credit broking, but the exclusions are narrow and conditional, so it's risky to assume:
- Genuine cash-only sales where finance is never discussed, arranged, or referred.
- Lending your own money that the customer repays directly to you — that's a different regulated activity (consumer credit lending), not broking, and it usually needs full permission rather than limited.
- Specific exemptions — for example, the new merchant carve-out for buy now, pay later ("deferred payment credit") from 15 July 2026, and certain interest-free agreements repayable in a small number of instalments within twelve months. These come with conditions. The BNPL carve-out applies to merchants offering it as a payment method — the FCA's final rules kept in-home sellers exempt too — but businesses introducing other kinds of regulated credit face restrictions on which exemptions they can use, especially when selling in customers' homes.
Because the exclusions are narrow and the cost of getting it wrong is high, treat "I think we're exempt" as something to confirm, not assume.
"But I don't take commission — surely I'm not a broker?"
This is one of the most common misconceptions. Whether or not you earn commission does not decide whether you're a credit broker. The regulated activity is the introduction itself; being paid for it isn't the test. Plenty of businesses that introduce finance for free — or that actually subsidise an interest-free deal out of their own margin — are still carrying out credit broking and still need authorisation.
Which permission do you need to do it?
If credit broking is secondary to your main business — you mainly sell goods or services and offer finance to help customers buy them — you'll usually qualify for the simpler, cheaper limited permission. If credit broking is your main business, you'll need full permission. Our guide to limited permission vs full permission walks through the distinction.
Why it matters
This isn't a technicality. Carrying out credit broking without the authorisation you need — and without operating as an appointed representative — is a criminal offence. It can also make the credit agreements unenforceable and expose your business to FCA enforcement. Working out whether you're a credit broker is therefore the first question to settle before you offer finance.
What to do next
The sequence is simple: work out whether you're credit broking (this guide), then which permission you need, then prepare and submit your application. Our step-by-step guide to getting authorised covers the whole process, and we've written sector-specific guides for car dealers, retailers, dentists and clinics, vets and home-improvement firms.
Frequently asked questions
- Do I need to take commission to be a credit broker?
No. The regulated activity is introducing the customer to a lender — being paid for it isn't the test. You can be credit broking even if you earn nothing from it, or if you subsidise an interest-free deal yourself.
- Is offering interest-free finance still credit broking?
Yes. Whether the customer pays interest, or you subsidise it so they don't, doesn't change the fact that you're introducing them to a lender — which is the regulated activity.
- What's the difference between credit broking and lending?
Broking is introducing or arranging finance with a third-party lender. Lending is providing the credit yourself so the customer repays you directly. They're different regulated activities, and lending usually requires full permission rather than the simpler limited permission.
- Does credit broking always need authorisation?
If you do it by way of business and no exemption applies, yes — either through your own FCA authorisation or as an appointed representative. A few narrow exemptions exist (such as the 2026 buy-now-pay-later merchant carve-out), but they're limited and conditional.
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.