HM Treasury publishes consultation on Appointed Representatives (AR) reform — what MGAs need to know
13th February 2026
HM Treasury has now issued its formal consultation on proposed changes to the UK Appointed Representatives (AR) regime, building directly on the August 2025 policy statement.
The changes fall into 3 broad areas:
A new FCA “gateway” permission for any firm acting as a Principal
The proposal intends to ensure only firms with the right expertise and resources can oversee ARs effectively. Existing Principals will be ‘grandfathered’ into the new regime – though further clarification will be needed on how this will operate. This will shape how MGAs acting as Principals will need to structure and evidence their AR oversight frameworks.
Direct FOS jurisdiction over ARs where the Principal isn’t responsible
This proposal aims to close longstanding redress gaps and reinforces the need for clear scope definitions and monitoring of delegated activity. Principals will no longer be pulled into investigations for which they bear no accountability. ARs will no longer escape responsibility for regulatory failings. The impact for an MGA will depend on whether they act as a Principal or an AR.
Alignment of AR conduct and fitness & propriety requirements with SMCR standards
The Consultation signals a move to a consistent regulatory approach across distribution chains, with ARs being brought within the SMCR framework. This is likely to be a significant cultural and operational shift, with open questions about proportionality for smaller ARs and how certification, Conduct Rules and responsibilities maps would apply in practice.
For MGAs — many of whom rely on AR distribution models — this consultation is a pivotal moment. It preserves the competitive advantages of AR networks, which are seen as helping drive the economic growth the government is committed to delivering, but raises the bar on accountability and risk management.
A more detailed analysis of the scope and key considerations for MGAs will follow in an article next week.
The HM Treasury consultation is open until 9 April 2026.
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