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Appointed representative oversight: the controls and the annual review checklist

This is the set of controls a principal firm runs across its appointed representatives, from appointment to termination. Each control has an objective, the evidence to keep, an owner role and a cadence. Alongside it are checklists for the two documents the FCA looks at most: each AR's annual review and the self-assessment your governing body approves. They follow the good practice the FCA described in its September 2024 review, and they add the inactive AR checks from April 2026. It is written for the compliance team that runs the oversight and the board that signs it off. It is built for networks of 20 or more ARs, where spreadsheets stop keeping up.

  • For Risk and compliance, Board
  • Format Checklist (PDF, about 4 pages) and XLSX template
  • Sources checked 15 Oct 2026

What is inside

  1. What the FCA found when it looked: the 2024 and 2026 reviews
  2. The rules behind the two documents: SUP 12.6A, in plain terms
  3. The controls, appointment to termination: 16 controls with objective, evidence, owner role and cadence
  4. Setting oversight intensity: three tiers for a network of 20 or more
  5. Checklist A: each AR's annual review
  6. Checklist B: the self-assessment your governing body approves
  7. Checklist C: inactive ARs
  8. What may change: the HM Treasury consultation
  9. The template (XLSX) and the checklist (PDF)

A sample

Control 9. Inactive AR review
Objective: every AR with no regulated activity in a period has a reason on file, in plain words, and a decision: keep, suspend with a documented plan, or terminate.
Evidence: the activity report by AR; the reason for each inactive AR; the decision and its date.
Owner role: AR oversight manager. Cadence: quarterly, and before each REP025 return.

The FCA's April 2026 review: "An unexplained lack of reported regulated activity is an indicator of weaknesses in principals' governance, monitoring and oversight."

Sources

FCA, Principal firms: embedding new rules for effective appointed representative oversight, 6 September 2024. FCA, Managing potential risks from inactive appointed representatives, 21 April 2026. FCA, PS22/11, 3 August 2022. FCA Handbook, SUP 12.6A. Checked 15 October 2026.

See a controls view worked through at Halden, our fictitious Lloyd's managing agent

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