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What AR Principal Firms Need to See Across Their Appointed Representatives

Last checked 10 October 2026 against the sources below

A principal firm answers to the FCA for every one of its appointed representatives. Here is what the FCA expects you to see, and to prove you saw it.

The Principal's Responsibility

An appointed representative (AR) carries out regulated activities under its principal's permissions, and the principal takes regulatory responsibility for what the AR does. The FCA strengthened the rules for principals in PS22/11, which came into force on 8 December 2022. The rules sit in SUP 12 of the FCA Handbook.

The FCA has found that principals and their ARs generate up to 400% more supervisory cases and complaints than directly authorised firms. That is why oversight of ARs is a supervisory priority.

What PS22/11 Asks Principals to Do

• Tell the FCA at least 30 days before a new AR appointment takes effect.
• Oversee ARs to a standard comparable to their own staff, with adequate systems, controls and resources.
• Monitor and assess the risk of harm each AR poses to consumers.
• Review each AR's activities, business and senior management every year.
• Prepare an annual self-assessment of how they meet the rules, signed off by their governing body and available to the FCA on request.
• Report complaints and revenue data for each AR every year.

Consumer Duty Applies to Every AR

The Consumer Duty applies to the regulated activities an AR carries out, and the principal is responsible for making sure it is met. That means a principal needs evidence of good outcomes across Products & Services, Price & Value, Consumer Understanding and Consumer Support, not just for its own customers but for every AR's customers too. The FCA has said firms should build Consumer Duty into their annual AR reviews.

What Good Oversight Looks Like

In its 2024 findings on how principals were applying the rules, the FCA found weak points that will be familiar to many networks: tick-box self-assessments, poor audit trails, over-reliance on ARs' own declarations, and slow action on problem ARs. The good practice it described included:

• Using a range of management information, such as complaint rates, revenue changes and staff turnover.
• Understanding each AR's business model, including any unregulated activity.
• Combining monitoring methods rather than relying on one.
• Treating a significant rise in an AR's complaints as a trigger for extra review.
• Keeping a clear record of what was found and what was done about it.

Warning Signs to Watch Across an AR Network

• A rise in complaints at one AR compared with the rest of the network.
• Complaints that are not closed within 8 weeks.
• Vulnerable customers identified at some ARs but never at others, which often means they are not being looked for.
• Renewal price increases without a recorded fair value check.
• Gaps in the evidence an AR sends, or evidence that arrives late.

What the Annual Self-Assessment Needs as Evidence

A self-assessment is only as strong as the evidence behind it. A governing body signing it off needs to see how each AR was monitored during the year, what was found, and what action followed. When that evidence is gathered by chasing spreadsheets from each AR, it is slow, incomplete and hard to trust.

How Omniron Helps

Omniron's Principal View shows every AR's complaints, vulnerability flags and Consumer Duty evidence in one place, built automatically from each AR's customer contacts. You can compare ARs side by side, spot the warning signs early, and give your governing body a self-assessment backed by a full audit trail.