Questions to ask before your practice works with a financial advice firm

Before a practice agrees to introduce clients to a financial advice firm, it can check the firm’s FCA permissions, who is responsible for the advice, how payments are disclosed to clients and what happens when the arrangement ends. The FCA, ICAEW and ACCA publish the rules behind each check.

16 min read · 25 October 2026 · Altro Partners, by Equity & General

A practice that introduces clients to a financial advice firm answers for the choice of firm and for anything it receives in connection with the introductions. ICAEW’s helpsheet on introductions to financial advisers requires a firm making an introduction to meet the Code of Ethics requirement to give objective advice (paragraph R331.19).

Put each question in writing to every firm you are considering, and keep the answers on file with the date. Those answers are the record your practice can show its institute, its professional indemnity insurer, or a client who asks why that firm was chosen.

FCA authorisation and permissions

Start with the FCA’s Financial Services Register or its Firm Checker. The FCA states that both show whether a firm is authorised or registered, and what products and services it is allowed to offer (FCA, How to check a firm or individual is authorised, updated 22 September 2026). Authorisation and permission are separate records, and the difference is set out in checking an adviser’s permissions.

Checking a firm on the register

Search by firm reference number. Ask the firm for its number and search on that, so the entry you read belongs to the legal entity that will give the advice.
Confirm the status. The FCA says a firm shown as “No longer authorised” or “Revoked” has had its authorisation cancelled.
Read the permissions. They list the regulated activities the firm may carry on. Advice on transferring out of a defined benefit pension needs its own permission and a specialist qualification.
Check for an appointed representative. The register names the principal. The FCA states that the principal agrees what the appointed representative can do and is responsible for that business, and that a client may lose Financial Ombudsman and FSCS protection if the appointed representative goes beyond it. Ask the principal to confirm the scope in writing.
Match the contact details. The FCA warns of clone firms that copy a genuine authorised firm, and says to check that the contact details you have been given match those on the register.
Look up the advisers. The FCA states that individuals can be checked on the Financial Services Register. Search for each adviser who will meet your clients.

Equity & General is directly authorised by the FCA under firm reference number 474163.

Regulatory responsibility and professional indemnity cover

Ask which legal entity gives the advice, writes the suitability report and holds the regulatory responsibility for it. For a directly authorised firm, that is the firm itself. For an appointed representative, it is the principal.

Then ask for evidence of professional indemnity cover. The FCA directs personal investment firms to chapter 13 of its Interim Prudential sourcebook for Investment Businesses (IPRU-INV 13). Its page on professional indemnity insurance (updated 25 February 2026) says a firm should have continuous cover since the start of its authorisation, a policy excess no higher than the specified minimum, and cover for Financial Ombudsman Service awards made against it. A policy must carry no conditions or exclusions which unreasonably limit its cover (IPRU-INV 13.1.20R). Ask whether the policy excludes any type of advice your clients are likely to need, such as pension transfers.

A directly authorised firm

Holds its own permissions, shown on the register under its own firm reference number.
Is responsible for the advice its advisers give and holds its own professional indemnity cover.
Ask for the firm reference number, the permissions that cover your clients’ needs, and the indemnity certificate.

An appointed representative

Carries on regulated activity on behalf of a principal, which agrees what the appointed representative can do.
The principal is responsible for that business, within the scope it has agreed.
Ask who the principal is, what the appointment covers, and for the principal’s confirmation in writing.

In an Altro partnership the advice is given under Equity & General’s own FCA permissions, the suitability report is written by Equity & General, and its professional indemnity cover stands behind the advice. The partner agreement records your firm’s role as the introduction.

Independent or restricted advice

ICAEW’s helpsheet on introductions to financial advisers links the objectivity requirement to the type of adviser. An introduction to an independent financial adviser who advises across all markets and all retail investment products is likely to meet it. For a restricted adviser, the firm must assess and document whether the adviser suits each client. FCA rules require advisers to disclose their status, and ICAEW says a firm can confirm it with the adviser, on the adviser’s website or in its other published material. Equity & General’s team page lists its financial advisers as independent financial advisers.

How fees and payments to your firm are disclosed

Two sets of rules apply, one to each firm. The advice firm’s charges are governed by the FCA’s adviser charging rules (updated 5 February 2026). The firm must disclose its charging structure upfront and in writing, in good time before the advice process starts. It must then disclose the total adviser charge for that client, in cash terms, before the client incurs any charges, and record the client’s agreement to the amount. Anything your practice receives in connection with an introduction is governed by your own institute’s rules.

ICAEW, unregulated introductions

Paragraphs 330.12 A1 to 330.13 A4 of the ICAEW Code of Ethics apply. The firm may keep a commission only with the client’s explicit written consent: specific consent for each amount, advance general consent, or consent after the event. Advance general consent in an engagement letter must state a range of likely amounts, and the client must still be told the exact amount received.

ICAEW, introductions under a DPB licence

Rule 4.15 of the DPB (Investment Business) Handbook requires the firm to disclose the amount and frequency in writing, tell the client they have the right to have the money paid over to them, and obtain express written consent to keep it. Consent is case by case. Until it is given, the money sits in a clients’ money account.

ACCA

ACCA’s factsheet Accounting to clients for commissions and referral fees (15 December 2024) requires written consent at the start of the engagement to keep any commission or referral fee. For exempt regulated activities, the engagement letter must give the nature, amount and frequency of the payment, and the client must be told at least once a year what was received.

ICAEW, Introductions to financial advisers helpsheet; ICAEW, Referral fees and commissions: client consent is your responsibility, February 2024; ACCA Designated Professional Body Regulations, regulation 3(7).

Ask the advice firm how any payment to your practice will appear in the documents the client receives, and check that its wording matches your engagement letter. The consent routes are set out in referral fees and client consent. In an Altro partnership your firm chooses one of two commercial models, Ongoing Income or Capital Value, and it is set out in the partner agreement before any introduction is made. The disclosure duties to your clients stay with your firm.

Who holds the client relationship

The client has two relationships: one with your practice for the accounts and tax, and one with the firm that gives the advice. Ask the advice firm whether it offers accountancy or tax services of its own, who the client contacts first, and how its advisers will refer to your practice when they meet the client.

Equity & General does not prepare accounts or file returns. The client’s Equity & General Account Manager contacts them because your firm asked, and is their main point of contact from then on. The client’s own financial adviser gives the advice. Client communications sent from the portal go out in your firm’s name.

Two colleagues in a meeting at a conference table

What your firm sees of each introduction

Ask what the advice firm will report to your practice for each client you introduce: whether the client was contacted, whether a meeting took place, what was recommended and whether it was put in place. Ask how it records the client’s agreement to that information being shared with you. A practice with that record can answer a client’s question months later and can show its institute or insurer what happened to each introduction.

In an Altro partnership each introduction is made through the portal in your firm’s name. The portal shows its stage from first contact to the advice being in place, with the recommendation recorded, and you can sit in on the client’s first meeting with the Account Manager. The steps are set out in how an introduction runs.

Complaints

Ask for the advice firm’s complaints procedure and who handles a complaint about advice given to a client you introduced. The Financial Ombudsman Service states that a business has up to 8 weeks to consider most complaints. A client with no response in that time can refer the complaint to the Ombudsman, and must do so within 6 months of the date on the final response. The service is free to the client (Financial Ombudsman Service, How to complain). Ask whether the advice firm will tell your practice when a client you introduced makes a complaint.

Client data and who controls it

Ask what client information your practice will send, what the advice firm will send back, and the role each firm takes under UK GDPR. The ICO defines controllers as the main decision-makers, which exercise overall control over the purposes and means of processing personal data, and processors as acting on behalf of, and only on the instructions of, a controller. Two controllers that jointly determine the purposes and means of processing the same data are joint controllers, and must arrange between them who takes primary responsibility for complying with UK GDPR (ICO, A guide to controllers and processors). Ask for the roles to be written into the agreement, with how a client’s request to see or delete their data is handled between the two firms.

If the advice firm fails

Ask where client money and investments are held, and by whom. Where a separate regulated firm holds them under the FCA’s client asset rules, they are kept apart from the advice firm, and those rules exist so that assets survive the failure of the firm dealing with them. If the advice firm fails owing a client compensation for bad advice, the claim goes to the Financial Services Compensation Scheme, within its limits.

£85,000

the most the FSCS can pay per eligible person, per firm, for investment claims where the firm failed after 1 April 2019

28 August 1988

advice must have been given on or after this date for a claim about bad advice that caused a loss

FSCS, What we cover: investments. The FSCS accepts no claims for poor investment performance alone.

What a practice needs on file when a firm stops trading is set out in when a client’s financial adviser goes into administration.

A hand signing a printed contract beside a notebook

Ending the arrangement

Ask what happens when either firm ends the arrangement: the notice each side gives, what happens to clients already introduced, whether payments to your practice continue, and what the advice firm will tell those clients. Ask the same questions about a sale or merger of the advice firm. The client’s advice relationship with the advice firm continues after the arrangement between the two firms ends, and the FCA’s adviser charging rules require a firm charging for an ongoing service to confirm how the client can cancel it.

In an Altro partnership a firm that wants to stop makes no further introductions. Pension and investment assets from your firm’s introductions are recorded against your firm, and their ownership is shared with Equity & General. If either side wants to sell its share, the other has first refusal at an independent valuation, and if it declines, both go to market together.

A worked example

This example uses two made-up advice firms and a made-up practice. A three-partner practice has sent the questions to two firms and set the answers side by side.

Question	Firm A	Firm B
Register status	Directly authorised, firm reference number supplied	Appointed representative; principal named on the register
Permissions	Advising on investments and pensions; defined benefit transfers included	Set by the principal; written confirmation of scope requested and awaited
Adviser status	Independent	Restricted
Professional indemnity	Certificate supplied; Ombudsman awards covered	Principal’s policy; certificate requested
Payment to the practice	Shown in a letter the practice sends, using its own engagement letter wording	Shown in the advice firm’s client agreement; the practice has seen no copy
Reporting to the practice	Stage of each introduction and the recommendation	A note when the client signs
Complaints	Procedure supplied; the practice is told of any complaint	Handled by the principal; no arrangement to tell the practice
Ending the arrangement	Written notice; introduced clients stay with Firm A	Answer awaited

The partner can introduce clients to Firm A once the answers are filed. Firm B has three open items: the principal’s confirmation of what the appointment covers, a copy of the client agreement showing how the payment to the practice is worded, and an answer on ending the arrangement. Because Firm B’s advisers are restricted, ICAEW’s helpsheet would also require the practice to assess and document, client by client, whether Firm B suits each one. The practice records the date of each answer and repeats the register check for both firms each year.

Questions to send each firm this week

What is your firm reference number, and are you directly authorised or an appointed representative? If an appointed representative, who is the principal and what does the appointment cover?
Do your permissions cover the advice our clients need? Please list the activities, including defined benefit transfers if our clients need that advice.
Which entity writes the suitability report and holds the regulatory responsibility?
Can we see your professional indemnity certificate, and what does the policy exclude?
Are your advisers independent or restricted?
How will your charges, and any payment to our practice, be shown to the client? Please send a copy of the wording.
What will you report to us for each client we introduce, and when?
Who handles a complaint, and will you tell us when one is made?
What client data passes between us, and which firm is controller for it?
Where are client assets held, and what happens to our clients if your firm is sold, merged or fails?
What happens to clients already introduced when the arrangement ends?

Common questions

Does an accountancy firm need a licence to introduce clients to a financial adviser?

It depends on the introduction. ICAEW’s helpsheet on introductions to financial advisers sorts each one by the type of product, whether the adviser is independent or restricted, and who makes the approach. A client who approaches an adviser directly is an unregulated introduction. A firm that approaches a restricted adviser on a client’s behalf about shares or funds needs a DPB licence, and the introduction must be incidental to the firm’s other professional services. A firm that approaches an adviser about insurance-based investment products needs FCA authorisation. Equity & General’s published position is that a partner firm needs no FCA permissions, and the partner agreement records the firm’s role as the introduction. Confirm your own firm’s position against your institute’s guidance before the first introduction.

Should a practice choose an independent or a restricted adviser?

ICAEW’s helpsheet sets the expectation that an independent financial adviser will offer the most suitable and objective advice, which is how paragraph R331.19 of the ICAEW Code of Ethics is met. A firm with particular reasons to introduce clients to a restricted adviser must assess, and document, whether that adviser suits each client, one client at a time, and ICAEW will ask to see that assessment after a complaint or during a Quality Assurance review. FCA rules require advisers to disclose whether they are independent or restricted, so the status can be confirmed from the adviser’s own disclosures. Equity & General’s team page lists its financial advisers as independent financial advisers.

Can the advice firm handle commission disclosure for us?

It can do the administration, and your firm keeps the responsibility. ICAEW’s Quality Assurance Department said in February 2024 that there is nothing wrong in principle with delegating disclosure to a third party, and that a firm relying on one must be satisfied it is doing everything required. When ICAEW visits, the onus is on the accountancy firm to show that any commission was disclosed as the rules require, and if the third party gets it wrong, regulatory action is taken against the accountancy firm. ICAEW also expects the firm to hold copies of all the documentation. Ask the advice firm for copies of every disclosure and consent it obtains for clients you introduced, and file them with your own record of the introduction.

Who is responsible if the advice turns out to be wrong?

The authorised firm that gave it. For a directly authorised firm that is the firm itself; for an appointed representative it is the principal, which the FCA says is responsible for the business it has agreed the appointed representative can do. A client with a complaint goes to the advice firm first and can then take it to the Financial Ombudsman Service, and the FCA expects a personal investment firm’s professional indemnity cover to include Ombudsman awards. What the accountancy firm said at the time of the introduction can still be examined, so keep a note of it. In an Altro partnership the suitability report is written by Equity & General, the advice is given under its FCA permissions, and its professional indemnity cover stands behind it.

What happens to clients we have introduced if the arrangement ends?

The client’s advice relationship is with the advice firm and continues after the two firms stop working together, so the agreement between the two firms needs to say what happens next. Ask whether payments to your practice continue, how the advice firm will describe the change to those clients, and whether your practice keeps sight of their position. The FCA’s adviser charging rules require an advice firm charging for an ongoing service to tell the client how to cancel it, so each client keeps that choice. In an Altro partnership the pension and investment assets from your firm’s introductions are recorded against your firm, and their ownership is shared with Equity & General. If either side wants to sell its share, the other has first refusal at an independent valuation.

Financial planning for your clients, alongside the accounts and tax work

Equity & General holds the FCA authorisation. There is no charge to your firm, and a named partnership manager works with you from the first introduction.