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Commercial Finance Launch Programme · Stage 3 of 10
Get Authorised
Do the work to be ready while the approval clock, the FCA’s, a network’s, a lender’s, ticks on someone else’s timetable, so you walk straight through each gate when it opens.
How long
Weeks of prep; approvals run weeks to months
You’ll have
A routed perimeter decision, a chosen route, and lender panels and a trade body under way
Steps
5 steps
Resources
4 resources
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01 Step 01
Step 01
Understand the regulatory perimeter
Commercial finance sits across a split perimeter, and where your mix falls decides whether you need FCA authorisation at all. This is the most consequential decision in the programme, and explicitly not one this programme makes for you.
Do it yourself
- Learn the shape at a signposting level only: purely commercial lending to limited companies (business loans, asset finance, invoice finance, commercial mortgages, development finance to a company) is largely outside the FCA’s regulated perimeter, while specific edges are regulated, namely consumer buy-to-let, regulated mortgage contracts, some bridging, and credit broking for individuals, sole traders and small partnerships.
- Map your intended product set and client type against those edges. Many "commercial" clients are sole traders, which can pull you into regulated credit broking.
- Take that map to the party who owns the answer, a network or principal, a compliance consultant, or the FCA, and let them confirm which permissions you need.
- Record their determination, because it drives everything downstream.
Common mistake · A founder deciding for themselves that "it is all commercial, so I do not need the FCA", then taking a sole-trader or consumer buy-to-let case that was regulated all along.
Time~1–2 days of prep CostThe determination is a paid conversation with a consultant or network, indicative low hundreds if standalone DifficultyHard conceptually, but the ruling is not yours to makeResource for this step
PDFPerimeter self-audit worksheet
List each product and client type; the sheet routes every row to confirm with your network, compliance or the FCA. It outputs questions to ask, never answers.
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02 Step 02
Step 02
Choose your authorisation route: AR, DA, or neither
If any part of your model is regulated you need permission, either as an Appointed Representative under a principal’s authorisation, or as a directly authorised firm, and each has real trade-offs.
Do it yourself
- Appointed Representative: operate under a principal or network’s permissions. Faster to start and a lighter compliance load, in exchange for less independence and ongoing network fees.
- Directly authorised: your own FCA authorisation. More control and credibility, against a substantial cost and administrative burden, and you own compliance.
- Or neither, if the owner in Station 1 confirms your mix is genuinely unregulated.
- Note the clock honestly: a DA application runs on the FCA’s timetable and AR onboarding on the network’s, weeks to months, their clock not yours.
- Get costs from at least two networks and price a DA route. FCA application fees are category-dependent, indicative low hundreds to low thousands; confirm on the FCA fees calculator.
- Decide with your compliance adviser and start the application early, so the third-party clock begins.
Common mistake · Choosing DA for the prestige without the compliance resource to run it, or choosing AR without reading how tightly the principal controls what you can do.
Time~2–3 days of your effort to compare and apply CostIndicative FCA and/or network fees; get live figures DifficultyHard; the approval time is the third party’s clockResource for this step
PDFAR vs DA decision matrix
Scores cost, control, speed, compliance burden and credibility for your plan, with a who-owns-compliance column.
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03 Step 03
Step 03
Get lender-panel access
Lender-panel access is the real crux, the equivalent of a network in financial advice. A new broker rarely has enough direct lender relationships, so access usually comes through a network, packager, master broker, aggregator, or trade-body panel. Without it, you cannot actually place deals.
Do it yourself
- List the lenders and products you need for your niche.
- Identify the routes to reach them: your network’s panel, a packager or master broker who holds the lender relationship, an aggregator or sourcing platform, or the NACFB and FIBA lender panels.
- Apply and onboard, noting each lender or panel runs its own onboarding checks on their clock.
- Keep a live panel register of who you are on, their appetite, and contacts.
Common mistake · Marketing a product you cannot actually place because you have no route to a suitable lender, generating leads you have to hand away.
TimeOngoing CostBundled into network or packager arrangements; indicative and varies DifficultyHard; onboarding time is the lenders’ clockResource for this step
PDFLender-panel access tracker
Columns for lender and product, route (network, packager, platform, direct), onboarding status, and appetite notes.
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04 Step 04
Step 04
Join the trade body: NACFB and/or FIBA
Trade-body membership provides compliance support, lender panels, PII schemes, credibility, and a "find a broker" listing. The two bodies are the NACFB (National Association of Commercial Finance Brokers) and FIBA (Financial Intermediary and Broker Association).
Do it yourself
- The NACFB is the largest general commercial-finance broker body (around 1,400 broker member firms), with the NACFB Mutual PII facility, a compliance and assurance process, and a public broker directory.
- FIBA is strong on specialist property finance (bridging, development, buy-to-let), with a compliance hub and helpline, the FIBA PI facility, the FIBA Academy, and lender panels.
- Prepare what they ask for: your FCA reference number and permissions, or if AR your AR agreement and your principal’s FCA details, plus PII and your ICO data-protection number.
- Complete the body’s onboarding on their clock, and join one or both depending on how property-heavy your niche is.
Common mistake · Assuming FIBA has merged or been absorbed. Both bodies are live and independent, and the change people misremember is a lender association (ASTL) rebranding to the BDLA, not a broker-body merger.
Time~1 day to apply CostNACFB indicative £72.25/month plus £24.75/month per additional broker; FIBA fees on application DifficultyMediumResource for this step
PDFTrade-body fit and application pack
An NACFB versus FIBA comparison against your niche, plus a document checklist for whichever you join.
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05 Step 05
Step 05
Meet competence expectations
There is no single mandatory qualification for pure commercial broking, but the moment you touch regulated mortgage work you need a recognised qualification, and networks, lenders and trade bodies carry competence expectations you must meet.
Do it yourself
- Confirm with your network or compliance whether your mix requires a regulated-mortgage qualification. CeMAP, the LIBF Level 3 qualification, is the standard for regulated mortgage advice and covers buy-to-let and consumer buy-to-let.
- Note that CeMAP is mid-transition: CeMAP 1 is replaced by FSRE (Financial Services Regulation and Ethics) under a new structure launched in late 2025, so do not treat the old three-module CeMAP as current.
- For specialist commercial or property work, consider the CPSP (Certified Practitioner in Specialist Property Finance), a Level 3 qualification run by FIBA with the BDLA and LIBF.
- Log which qualification, if any, your route requires and your study plan, but let the network or body confirm the requirement.
Common mistake · Assuming "commercial means no exams", then discovering a regulated case needs a qualified adviser you do not yet have.
TimeStudy is weeks of effort CostCeMAP indicative several hundred to around £1,000 or more; CPSP on application; get current prices DifficultyMedium to hard; your network or body confirms the requirement
What you’ll have after this stage
- A perimeter self-audit routed to the right owner for a decision
- A chosen route (AR, DA, or unregulated), with the reasons recorded
- Lender-panel access under way
- Trade-body membership applied for
- A clear read on which qualification, if any, your mix needs