Article 67
exclusion refers to the carve‑out that allows a non‑investment business to carry on limited investment activities that are necessary to deliver its main service, without separate FCA authorisation. In practice, it can exclude the regulated activities of dealing,
arranging deals in investments, and safeguarding and administration of assets, where those steps can reasonably be regarded as a necessary part of the other services provided in the course of that business. It typically requires that the
activity is ancillary to the core service, not separately remunerated, and not held out as a standalone investment service.
This exclusion is defined in Article 67 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO) (as amended). It does not extend to all regulated activities (for example, advising on or managing investments fall outside its scope), and it is construed narrowly.
The concept and its legal effect are consistent across England and Wales, Scotland and Northern Ireland. There is no direct Irish equivalent labelled “Article 67 RAO”; Irish firms must assess incidental or ancillary exemptions under the Irish regulatory regime (MiFID II/Investment Intermediaries Act) and Central Bank requirements. Careful scope analysis and documentation are essential.