Most of the caution an accountant feels about introducing a client to a financial planner is caution about the wrong thing. The worry is usually that the introduction itself carries some regulatory weight — that pointing a client towards regulated advice is a step across a line. It is not. The line that actually matters sits one layer further in, and an FCA decision published this morning is a clean illustration of it: the question is not whether a firm is authorised, but whether it is permitted to do the specific thing your client is about to ask it to do.
That distinction is invisible in ordinary practice. A client mentions that someone helped them with a pension, or that the firm they are seeing is regulated, and the sentence sounds complete. It is not complete. Authorisation and permission are two different records, held in the same place, and only one of them answers the question a practice is really asking when it decides which firms it is prepared to put in front of clients. This is the week to look up the firms you already use, and the case below explains why.
What the FCA has decided
On 3 September 2026 the FCA published its decision to ban Daniel Thomas from working in financial services and to fine him £742,700, after finding that he recklessly gave defined benefit pension transfer advice he was neither qualified nor allowed to give. Mr Thomas has referred the Decision Notice to the Upper Tribunal, where he will present his case. The FCA is explicit that its findings are provisional as a result, that they reflect the FCA's belief as to what occurred, and that no action will be taken until the Tribunal reaches its decision.
The facts the FCA sets out are these. Mr Thomas was a director and financial adviser at DPT Financial Solutions Limited. Over five years he advised 53 clients about 63 transfers out of defined benefit pension schemes, and is believed to have earned more than £173,000 in fees. The FCA states that he repeatedly misled clients and pension providers about his professional qualifications, destroyed client records, and failed to co-operate with the investigation. Therese Chambers, the FCA's executive director of enforcement and market oversight, said he had "recklessly betrayed that responsibility".
The detail an accountant should stop on is the structural one. DPT Financial Solutions was an appointed representative. That meant another authorised firm — a principal — was responsible for overseeing what it did, and the FCA states that Mr Thomas provided misleading information to that principal about his involvement in the pension transfer cases. The oversight structure was in place. What defeated it was information moving through it that was wrong.
The word doing the work is "allowed"
The FCA's own framing of why this matters is worth reading slowly, because it is a statement of general rule rather than a comment on this case. It is not normally in consumers' best interests to transfer out of a defined benefit pension, because those schemes provide valuable guaranteed benefits which increase annually. That is why only advisers with specialist qualifications and the correct permissions can advise on whether to transfer out.
Two gates, in other words, not one. The firm must hold the permission, and the individual must hold the specialist qualification. A firm that is genuinely, currently authorised by the FCA can still be a firm that is not permitted to advise on a defined benefit transfer, and nothing about the phrase "they're FCA regulated" distinguishes between those cases. The Financial Services Register records both halves — it shows whether a firm is authorised and what regulated activities it is permitted to carry on — and the FCA has built a consumer tool around precisely this point, designed to make it easier to check whether a firm is authorised and has permission for the service it is offering.
Authorisation is the gate. Permissions are the rooms behind it, and they are not the same for every firm that got through the gate.
Why the appointed representative structure matters to an introducer
Appointed representatives are common in UK financial services and there is nothing irregular about the model. An AR carries on regulated activity under the responsibility of an authorised firm, the principal, and the FCA's published expectations of that principal are specific. It must have a written AR agreement setting out what business the AR can do. It must assess the AR before appointing them, to establish that they are fit and proper, financially stable and suitable to carry out business for the firm. It must notify the FCA at least 30 days before the appointment takes effect. It must take reasonable steps to ensure the AR acts within the scope of their appointment, and it must ensure the AR continues to meet the necessary standards, including the Consumer Duty, for the regulated activities it has accepted responsibility for.
The phrase carrying the weight there is scope of their appointment. An AR's boundary is not the principal's full permission set; it is whatever the written agreement between them covers. A practice that looks up a firm, sees a principal with wide permissions and stops reading has answered a question it did not ask. The useful question — who is the principal, and what does the appointment actually cover — is a two-line email, and it is the sort of thing that belongs on file once per firm, not once per client.
A worked example of the check
The following is illustrative — a composite built to show the shape of the exercise, not a real client and not a comment on any particular firm.
A client of a three-partner practice is 58, has been offered a redundancy package, and mentions in a year-end meeting that she has a deferred defined benefit pension from an employer she left in 2004 and is "looking into moving it". She has already spoken to someone. The partner has fifteen minutes and no regulated permissions of his own. Here is what the fifteen minutes can usefully contain.
- Establish which firm, by name. Not the individual's first name, and not the trading name on an email signature — the legal entity, and its firm reference number if she has it.
- Look it up on the Financial Services Register. Confirm it is authorised, and read what it is permitted to do. If the entry shows an appointed representative, note the principal and treat the scope question as open rather than answered.
- Note the specific activity. A defined benefit transfer is not general investment advice. If the permission for it is not visible, that is the finding, and it is a finding worth having before rather than after.
- Say nothing about the merits. Whether the transfer is a good idea for her is a regulated question with a statutory starting assumption against it, and it belongs entirely to a qualified, permitted adviser.
- Write down what happened. Date, firm, what was looked up, what was said, what she agreed could be passed on. Four lines.
Nothing in that sequence requires a permission the accountant does not have, and nothing in it is advice. It is the difference between a client walking into a conversation the practice has never examined and one it has. The boundary between the two roles is set out in more detail in who does what, and the mechanics of recording an introduction properly in the anatomy of an introduction.
Two things worth doing this week
Look up the firms the practice already introduces to. Not the clients — the firms. Most practices deal with a handful, so this is a short exercise done once. Confirm each is authorised, read what it is permitted to do, note whether it is an appointed representative and who its principal is, and save the result with the date. A page of notes covering five firms is the whole job, and it converts an informal habit into a decision the practice can describe.
Decide what the practice says out loud about defined benefit schemes. Deferred final salary pensions surface constantly in year-end conversations, redundancy discussions and divorce work. A practice that has agreed a form of words — that this is specialist, permitted advice, that the starting position in the rules is against transferring, and that the practice does not comment on the merits — has removed the improvised sentence that causes the trouble. This is the same discipline described in what happens when an adviser firm fails, applied a step earlier.
What is not yet settled
The case itself is live and should be described that way. The findings are provisional pending the Upper Tribunal, no hearing date has been published, and the Tribunal's decision will appear on its own website when it comes. The FCA has not named the principal firm in its press release, and it has not said what supervisory consequence, if any, follows for that firm. Anyone tracking the case should follow the FCA's press release and the Tribunal's published decisions rather than treat the September position as final.
What is not provisional is the structure underneath it: the Register, the permission regime, the specialist qualification requirement for defined benefit transfers, and the published duties of a principal firm towards its appointed representatives. Those are settled, public, and the same today as they were before this decision. They are the part a practice can act on.
The wider point
It would be an easy and wrong conclusion to read a case like this as a reason to make fewer introductions. The lang cat's State of Advice Report 2025 found that just 9% of UK adults had paid for financial advice in the preceding two years, while 91% of those who took advice found it valuable, in a market of fewer than 5,000 IFA firms with an average new client portfolio of £411,000 and an average client age of 59. A shortfall of that shape — set out in more detail on the advice gap — is not closed by professionals becoming more reluctant to point people towards help.
It is closed by the pointing being done well. The client in the composite above was going to look into her pension either way; the only variable was whether anyone she trusted had checked what the firm she found was permitted to do. That check costs a practice a few minutes per firm and, on the evidence of this decision, is the exact thing that was absent for 53 people over five years. Accountants are unusually well placed to make it, because they see the deferred scheme in the paperwork long before anyone else does — which is the whole argument for the two professions working from the same picture rather than in sequence.
Common questions
What is the difference between a firm being authorised and holding the right permission?
Authorisation is the gate; permissions are the rooms behind it. A firm on the Financial Services Register has been authorised by the FCA, but the Register also records the specific regulated activities that firm is permitted to carry on, and those vary enormously between firms. A firm authorised to advise on investments is not thereby permitted to advise on transferring out of a defined benefit pension, which is a separate permission requiring specialist qualifications on top of it. The FCA’s own consumer tool is built around exactly this distinction: it checks whether a firm is authorised and whether it has permission for the service being offered. Reading only the first half of that answer is the common error.
What is an appointed representative, and why does it matter when introducing a client?
An appointed representative carries on regulated activity under the responsibility of an authorised firm, known as the principal. The principal must have a written AR agreement setting out what business the AR can do, must assess the AR as fit and proper before appointing them, must notify the FCA at least 30 days before the appointment takes effect, and must take reasonable steps to ensure the AR acts within the scope of that appointment. For an introducer this matters because the scope of the appointment, not the principal’s full permissions, is the boundary of what the AR may actually do. Asking who the principal is, and what the appointment covers, is a two-line email.
Is an accountant expected to police what an adviser is permitted to do?
No, and it would be wrong to describe the check that way. Responsibility for staying within permissions sits with the authorised firm and, where relevant, with its principal. What an introducing accountant controls is narrower and entirely practical: which firms the practice is willing to introduce clients to, and whether that decision was made on the basis of anything recorded. Looking a firm up on the Financial Services Register and noting what it is permitted to do takes a few minutes once per firm, not once per client. It is due diligence on a business relationship, of the same kind a practice already applies to any professional it works alongside.
Why are defined benefit transfers treated so differently from other advice?
Because of what is being given up. The FCA’s position, stated again in this decision, is that it is not normally in consumers’ best interests to transfer out of a defined benefit pension, since those schemes provide valuable guaranteed benefits which increase annually. That is why only advisers with specialist qualifications and the correct permissions can advise on whether to transfer. The consequence for an accountant is that a defined benefit scheme in a client’s paperwork is not an ordinary planning signal. It is the one area where the question of what the adviser is specifically permitted to do should be settled before a conversation starts rather than after it.
What should a practice record when it introduces a client to a financial planner?
Five things, all short. Which client, on what date, to which firm, what the client agreed could be passed on, and what the practice said the introduction was. That last item is the one that gets skipped and the one that matters, because it is the difference between offering a client a door and endorsing an outcome. Alongside it, keep a single note per firm rather than per client, recording that the firm’s authorisation and permissions were looked up, when, and what they covered. A practice that keeps both can describe every introduction it has made in about forty minutes. A practice that keeps neither cannot describe them at all.
Does a provisional FCA decision mean the findings are established?
It does not. In this case the FCA has issued a Decision Notice and the individual has referred it to the Upper Tribunal, where he will present his case. The FCA is explicit that its findings are therefore provisional, that they reflect the FCA’s belief as to what occurred and how it considers the behaviour should be characterised, and that no action will be taken until the Tribunal reaches its decision, which will be published on the Tribunal’s website. Commentary on a case at this stage should describe the allegations as allegations. The underlying regulatory structure the case illustrates, in contrast, is settled and published.