Appointed Representative (AR)
A UK firm that carries on regulated activities under FSMA as the representative of an authorized principal firm. The principal accepts regulatory responsibility for what the representative does, and the representative holds no authorization of its own.
Also called: appointed representative · AR
The appointed representative regime is a route into the UK regulated sector without a firm applying for its own authorization. A principal firm authorized by the Financial Conduct Authority appoints the representative, records the appointment, and answers to the regulator for the representative’s regulated conduct. The representative’s permission to act is borrowed, and it ends when the principal ends the appointment.
Why the distinction matters
An appointed representative is a creature of FSMA, which covers regulated activities such as insurance distribution, investment advice and consumer credit broking. Payment services and electronic money sit under their own regimes, and a firm acting for another in those activities is a payment services agent or an EMI agent, not an appointed representative. The three are used interchangeably in commercial conversation. They are not interchangeable in law, and the register entry, the paperwork and the liability each differ.
A firm offered “AR status” for a payments or e-money business should establish which regime the sponsor is actually operating under before signing anything.
In practice
An appointed representative operates under FSMA for regulated activities. Payment services and e-money agency sit under the payment services and e-money regimes instead, so an appointed representative is not the UK counterpart of a US authorized delegate and should not be treated as one when structuring a payments business.
Example
A UK insurance broker appointed by an authorized principal can distribute insurance under that principal’s permissions. A payments startup wanting to hold and move customer funds cannot use the same route. It must be registered as the agent of an authorized payment institution or electronic money institution, which is a different status recorded separately on the Financial Services Register.
Commonly confused with
| Term | How it differs |
|---|---|
| Authorized Delegate | An authorized delegate is a US state money transmission status; an appointed representative is a UK FSMA status, and neither is recognized in the other’s jurisdiction. |
| EMI Agent | An EMI agent provides payment services for an electronic money institution under the e-money regime, while an appointed representative acts under FSMA for activities that regime does not cover. |
See also
- Payment Services AgentA payment services agent is a person that provides payment services on behalf of a payment institution, an electronic money institution or a registered account information service provider. The principal applies and the FCA decides; the agent is entered on the register, works under the principal’s permissions, and the principal answers for what it does.
- EMI AgentA firm through which an electronic money institution provides payment services in the UK. The EMI applies for the agent’s registration and the FCA registers it; the agent holds no authorization of its own, acts under the institution’s permissions, and the EMI remains responsible for everything the agent does or fails to do.
- Financial Conduct AuthorityThe Financial Conduct Authority is the United Kingdom’s conduct regulator for financial services. It decides whether a payments or e-money firm may operate in the UK, authorizes or registers it, and supervises how it behaves afterwards.
- Authorized DelegateA company authorized to conduct money transmission on behalf of a licensed principal, operating under that principal’s money transmitter license rather than holding one of its own. Most US states call this an authorized delegate; some call it an agent.
Go deeper
Regulatory information checked: 22/Sep/2026