The Regulatory Baseline: Why FCA Rules Apply to You
Many renewable energy installers are surprised to learn that the Financial Conduct Authority's rules on consumer credit apply to them — even though they're not a bank or a finance company. The key is the concept of 'credit broking'. Under UK law, any business that introduces a consumer to a source of credit in relation to goods or services is carrying out a regulated activity.
This means that if you recommend, suggest, or even just hand a customer a leaflet about a finance option linked to your installation, you are technically broking credit. Doing so without the correct regulatory permissions is a criminal offence under the Financial Services and Markets Act 2000.
The good news is that the pathway to compliance is well-established and, with the right partner, doesn't need to be complicated or slow.
The Two Main Routes to Compliance
There are two primary ways a renewable energy installer can legally offer finance to customers: holding your own FCA authorisation, or operating as an Appointed Representative of an already-authorised firm.
Route 1: FCA Authorisation — Limited Permissions
Limited Permissions credit broking is the FCA authorisation type designed for businesses where credit broking is not the core activity — such as a solar installer or heat pump specialist. It allows you to introduce customers to a lender or broker for the specific goods or services you provide.
To apply for Limited Permissions, you submit an application through the FCA's Connect portal. The application asks you to describe your business model, confirm your compliance arrangements, declare key personnel, and pay an application fee (currently £250 for most Limited Permissions applicants).
The FCA typically takes 3–6 months to process an authorisation application, though timelines can vary. During that time you cannot legally broker credit. Once authorised, you will appear on the FCA Register — a public record of all authorised firms.
Route 2: Appointed Representative (AR) Arrangement
An Appointed Representative arrangement is faster and simpler. Under this model, an already-authorised firm (the 'principal') takes regulatory responsibility for your credit broking activities. You don't apply to the FCA directly for this — instead, you enter into a written AR agreement with the principal firm, who registers you with the FCA as their AR.
The key benefit is speed: you can be compliant and trading within days rather than months. The principal firm is responsible for ensuring your activities comply with FCA rules, providing training, and monitoring your conduct.
Rubix Finance offers an AR arrangement for installer partners. When you join our network, you introduce your customers to our FCA-authorised platform — and we handle the regulatory oversight, compliance monitoring, and lender relationships.
What the FCA Expects from Credit Intermediaries
Whether you hold your own authorisation or operate as an AR, the FCA's standards apply to how you conduct your credit broking activity. The following are the most relevant requirements for installers.
Consumer Duty
The FCA's Consumer Duty, which came into force in July 2023, sets a higher standard of consumer protection across financial services. In practice, this means you must ensure the finance products and information you present to customers are genuinely suitable for their needs, that communications are clear and not misleading, and that customers can always understand what they're agreeing to.
For installers, Consumer Duty compliance means presenting finance options honestly — showing representative examples of monthly costs, not cherry-picking the most attractive figures — and never pressuring a customer to apply.
Financial Promotions
Any communication that promotes a financial product must be 'fair, clear, and not misleading'. This includes your website, social media posts, leaflets, and anything you say on-site about finance. The rules are specific: you must include a representative APR when you quote a rate, show typical monthly payment calculations based on realistic assumptions, and make clear that the finance is provided by a lender (not by you).
Most installer partners source compliant financial promotion templates from their broker partner. Rubix Finance provides ready-to-use materials that have been reviewed for FCA compliance.
Disclosure Requirements
You are required to disclose to customers that you are acting as a credit intermediary (not a lender), identify the lender(s) your customers may be introduced to, and disclose any commission you receive for successful introductions. Commission disclosure became more stringent following the FCA's review of motor finance in 2024, and the direction of travel across sectors is toward greater transparency.
Your broker partner will typically provide standard disclosure wording for you to use. Do not improvise — use the approved language.
The FCA Authorisation Application: What to Prepare
If you decide to pursue your own Limited Permissions authorisation rather than the AR route, here is what you'll need to prepare before submitting through the FCA Connect portal.
Business Description and Model
You will need to describe your business clearly: what you install, how you currently sell, and how finance fits into your process. Be specific about the credit broking activity — that you will introduce customers to a named broker or lender panel in connection with renewable energy installations.
Compliance Arrangements
The FCA will ask how you will ensure your credit broking activities comply with their rules. At minimum, you need a written compliance policy covering financial promotions, disclosure, complaints handling, and how you will keep records of finance introductions. For Limited Permissions, this doesn't need to be an elaborate manual — but it needs to be genuine.
Fit and Proper Assessment
All directors and key personnel involved in regulated activity must pass a 'fit and proper' test. The FCA checks for criminal convictions, civil judgements, regulatory history, and financial soundness. You will complete a personal questionnaire for each relevant individual as part of the application.
Professional Indemnity Insurance
Limited Permissions firms must hold adequate professional indemnity insurance (PII) covering their regulated activities. The minimum levels are set by the FCA, and you'll need to declare your PII as part of the application. Check that your existing business insurance covers credit broking activity — it often doesn't as standard.
Getting Support Through the Process
FCA authorisation applications are manageable but time-consuming. Common reasons for delays or rejections include incomplete answers, vague compliance arrangements, or inadequate disclosure policies. Using a structured template and having an experienced reviewer check your application before submission significantly improves outcomes.
Rubix Finance provides guidance and practical support to installer partners pursuing their own Limited Permissions authorisation — covering application preparation, compliance policy templates, and FCA communications. For installers who prefer the faster route, our Appointed Representative arrangement gets you trading legally within days.
Key Takeaways
You need FCA authorisation (or an AR arrangement) before you can legally introduce customers to finance in connection with your installations.
Limited Permissions credit broking is the appropriate authorisation type for installers. It takes 3–6 months and costs £250 to apply.
The Appointed Representative route is faster — you can be live in days — by partnering with an FCA-authorised credit broker like Rubix Finance.
Once authorised or registered as an AR, you must meet ongoing FCA standards including Consumer Duty, financial promotion rules, and disclosure requirements.
Rubix Finance supports installer partners through both routes, from AR onboarding to full authorisation preparation.