The operating system for introducer-led growth
RQ helps professional firms send, manage, and prove referrals — with built-in compliance, clear tracking, and real visibility across the firm.
Is making referrals to financial advisers considered investment business?
Category: ICAEW & RQ
Making a simple referral to an FCA-regulated financial adviser is generally not considered investment business activity and does not require a DPB licence. However, the distinction is important. <strong>What is exempt (Schedule 4 of the DPB Handbook):</strong> A "generic referral" where you simply pass on a client's name and contact details to an adviser, without providing any view on the suitability of investments or specific advice, is exempt from regulation. This is sometimes called a "bare introduction". <strong>What may require a DPB licence:</strong> If you go beyond a generic referral by discussing the client's investment needs, commenting on whether particular investments might be suitable, or recommending specific advisers based on their investment offerings, you may be conducting a regulated activity that requires a licence. <strong>The key test:</strong> Does your referral involve any element of investment advice or suitability assessment? If so, it likely falls within regulated activity. RQ helps firms document and evidence that referrals are compliant introductions rather than regulated advice, providing clear audit trails that demonstrate the nature of each referral.