Our finance is 0% APR over 24 or 36 months. Do we still need a licence?

Yes. The exemption only covers interest-free credit within 12 months and 12 instalments. A 24- or 36-month plan is a regulated credit agreement even at 0% APR, and offering it to customers is regulated credit broking — which is why the national jewellery chains all hold FCA permissions as credit brokers.

Is Klarna Pay-in-3 at our checkout exempt?

Generally yes on the merchant side — interest-free pay-in-3 offered as a payment method is exempt, and stays exempt under the rules taking effect 15 July 2026, which regulate the BNPL lenders instead. But the exemption only protects you if everything you offer fits inside it; add a longer or interest-bearing plan and you need authorisation.

Do jewellers need a money-laundering registration to offer finance?

Offering finance doesn't trigger one — credit broking is the FCA's regime, and pure broking sits outside the Money Laundering Regulations. Separately, if you accept cash payments of €10,000 or more (single or linked), you must register with HMRC as a high value dealer. The two regimes are independent: check each on its own terms.

Does limited permission cover pawnbroking or lending against jewellery?

No. Pawnbroking is regulated consumer credit lending and sits outside the limited permission regime — it needs full permission. Buying items outright from customers and taking part-exchange aren't credit at all, so neither needs a licence.

When a Car Dealer Can't Have Limited Permission

Limited permission is the cheaper, lighter route — and most car dealers qualify for it. But three specific situations disqualify a dealership entirely, and the most common one catches firms that already sell GAP or warranty products. Here is each of them, what the FCA actually says, and what to do instead.

The short answer

Most motor dealers qualify for limited permission credit broking, because arranging finance is secondary to selling vehicles. It costs less, the application is lighter, and the ongoing reporting is smaller.

But you cannot hold limited permission if any of the following is true:

You are directly authorised by the FCA for general insurance — GAP, warranty, tyre-and-alloy cover sold under your own permission
You lend your own money on interest-bearing terms, or on hire purchase or conditional sale
You are a domestic premises supplier — you sell to customers in their homes

Each forces full permission instead, or a restructure. Applying for limited permission when one of these applies wastes the application fee and the months waiting for a decision.

Trap one: you are already authorised for insurance

This is the one that catches most dealers, and it is not obvious.

If your dealership sells GAP insurance, extended warranty or similar products under its own FCA authorisation for insurance distribution, you cannot also hold limited permission for consumer credit. The FCA is explicit: you can combine limited permission for credit with being an appointed representative for insurance distribution — but you cannot combine limited permission for credit with full permission for insurance or other regulated activities.

In other words, the two directly authorised permissions do not sit together.

Your options are:

Apply for full permission for credit, and keep your direct insurance authorisation. Heavier application, higher annual fees, closer supervision.
Become an appointed representative for the insurance side — usually through the provider whose products you sell — and apply for limited permission for credit. Most dealers who discover this take this route, because limited permission is materially cheaper to hold.

Worth checking before you apply: look your firm up on the Financial Services Register and see what permissions you actually hold. Plenty of dealers assume they are an AR when they are directly authorised, or the reverse.

Trap two: you lend your own money

If customers repay you rather than a finance house, you have moved from broking into lending — and lending is a different permission.

The FCA allows this within limited permission only in a narrow case: you must be the supplier of the vehicles you are selling, and your lending must be always free of interest and charges, and never hire purchase or conditional sale.

That is a tight box. Charge interest, add a fee, or structure it as HP, and you need full permission with lending permissions, plus a business plan demonstrating you meet the FCA’s creditworthiness rules — a proportionate assessment of whether the customer can afford the repayments, and an assessment of the credit risk you are taking.

In-house finance is a legitimate model. It is simply not a limited permission one, unless it is genuinely free.

Trap three: you sell at the customer’s home

A domestic premises supplier is a firm that sells goods or services to customers in the customer’s home. Those firms need full permission credit broking, not limited.

For most dealers this does not apply — the sale happens on the forecourt. But it is worth thinking about if you have moved towards home delivery with the paperwork completed at the doorstep, or if a salesperson visits customers to close deals. The question is where the sale is agreed, not where the vehicle ends up.

If you are unsure, our guide to domestic premises suppliers covers the test in more detail.

What this costs if you get it wrong

The FCA application fee is not refundable if your application is withdrawn or refused. Applying for the wrong permission means paying it, waiting, and then starting again — on a decision timeline that is entirely the FCA’s.

It also puts a refused or withdrawn application on your record, which the FCA will see next time.

None of the three traps above is hard to check. They are just easy to miss, because the obvious question — “do I need authorisation?” — gets answered before the more specific one: “which kind, and am I eligible for it?”

What to do next

Check the Financial Services Register for what your firm currently holds. Then look at how you sell finance and insurance, and where.

If none of the three traps applies, limited permission is almost certainly right for you, and our guide to FCA authorisation for car dealers covers what the application involves.

If one does apply, it changes the shape of the application rather than ruling it out — and it is far better to find out now than four months in.

Frequently asked questions

We sell GAP insurance. Does that automatically block limited permission?

Only if you sell it under your own direct FCA authorisation for insurance. If you are an appointed representative of the insurance provider, you can still apply for limited permission for credit — the FCA permits that combination.

Can we drop the insurance permission to qualify?

You can apply to cancel or vary a permission you no longer need, or move to appointed representative status for the insurance side. Which makes sense depends on how much of your income comes from insurance products.

What if we only offer finance occasionally?

Frequency does not change whether you need authorisation. Introducing even one customer to a lender is credit broking. What frequency affects is whether broking is secondary to your main trade — which is the test for limited rather than full permission.

Does part-exchange with outstanding finance need a separate permission?

Usually yes. Settling existing finance on a trade-in vehicle can amount to debt adjusting and debt counselling, and both can sit within limited permission. It is worth scoping them into the application rather than discovering the gap later.

This article is general information to help you understand the process, and is not legal or regulatory advice. CreditLicence is a document preparation service and is not affiliated with, endorsed by, or acting on behalf of the Financial Conduct Authority. FCA rules can change; always check the FCA's website for the current position.

When a car dealer can’t have limited permission