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Dealing as agent meaning

What does Dealing as agent mean?
Acting on a client’s behalf to execute transactions in investments, rather than on the firm’s own account. In practice this covers a broker or intermediary who buys, sells or subscribes for investments, or underwrites an issue, as agent for a client, creating rights and obligations for the client. In England & Wales, Scotland and Northern Ireland, this is a regulated activity defined in article 21 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001. It concerns “securities” and “contractually based investments” as defined in the RAO. Firms require FCA authorisation/permission for “dealing in investments as agent” (subject to applicable exclusions) and must comply with conduct requirements such as best execution and client order handling. It is distinct from dealing as principal and from arranging deals. In Ireland, the concept is not a standalone defined term but corresponds to MiFID II investment services, particularly “execution of orders on behalf of clients” and, where relevant, “underwriting/placing”. Irish firms require authorisation from the Central Bank of Ireland for those services. Usage and legal effect are broadly consistent across the jurisdictions.
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NEWS
Financial services regulatory update: FCA cryptoasset perimeter consultation, AML synthetic data, Hartley Pensions enforcement, ESMA reporting guidance, cross-border G-SIB resolution, ISLA netting opinions (15 April 2026)

Financial services developments FCA consults on crypto regime perimeter guidance The FCA has opened a consultation on draft perimeter guidance for the UK’s forthcoming crypto regime. It indicates that consultations on rules for the future cryptoasset framework are largely complete, with policy statements planned for summer 2026. This guidance consultation complements that work by clarifying which activities sit within scope, with a final policy statement expected in autumn 2026. Responses are requested by 3 June 2026. Feedback is invited on the FCA’s interpretation of the perimeter for the following regulated cryptoasset activities: issuing qualifying stablecoins in the UK safeguarding, or arranging the safeguarding of, qualifying cryptoassets and relevant specified investment cryptoassets running a qualifying cryptoasset trading venue dealing in qualifying cryptoassets as principal dealing in qualifying cryptoassets as agent arranging transactions in qualifying cryptoassets arranging staking of qualifying cryptoassets Sources: FCA consults on guidance on the UK’s future crypto regime; CP26/13: Cryptoasset perimeter guidance. The...

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View the related Practice Notes about Dealing as agent

PRACTICE NOTES
UK regulated activity of managing investments: FSMA 2000 RAO article 37—scope, discretion, qualifying investments, exclusions and FCA conduct requirements

This Practice Note addresses the regulated activity of managing investments... Definition Managing investments is a regulated activity under article 37 of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, SI 2001/544 (RAO). It entails exercising discretion over assets that beneficially belong to another person, where those assets consist of, or include, any investment categorised as a ‘security’, a ‘structured deposit’ or a ‘contractually-based investment’. For further detail on what constitutes a ‘security’, a ‘structured deposit’ or a ‘contractually-based investment’, see Securities, structured deposits or contractually-based investments below)... The exercise of discretion This regulated activity only arises where the investment manager exercises discretion. Where portfolio management is non-discretionary—for example, the manager purchases shares strictly on client instructions, or simply receives and forwards client orders—the work is more likely to fall within another regulated activity, such as ‘dealing in investments, either as principal or agent’ (RAO SI 2001/544, arts 14 and 21) or ‘arranging deals in investments’ (RAO SI 2001/544, art 25)...

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PRACTICE NOTES
UK Regulated Activities Order (RAO) exclusions for insurance-related regulated activities: FSMA 2000 scope, IDD implementation and override, and effecting/carrying out, arranging, dealing, managing, assisting and advising

The general prohibition Under section 19 of the Financial Services and Markets Act 2000 (FSMA 2000), no person may undertake regulated activities in the UK unless they are authorised or fall within an exemption. This is referred to as the general prohibition. For guidance on the territorial reach of this restriction, see Practice Note: Territorial scope of the prohibition. Under FSMA 2000, s 31, an authorised person is one who: has been granted permission by the Financial Conduct Authority (FCA) or the Prudential Regulation Authority (PRA) under FSMA 2000, Pt 4A to carry on specified regulated activities; or is a Gibraltar-based person with a Schedule 2A permission to carry on one or more regulated activities. Please note that this latter provision, inserted by section 22(1), (2) of the Financial Services Act 2021, is not yet in force...

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PRACTICE NOTES
UK Coronavirus Job Retention Scheme—original March–June 2020 version: eligibility, employee categories, calculations, TUPE, furlough agreements, claims and Treasury Directions [Archived]

ARCHIVED This archived Practice Note is not being maintained and is supplied for background purposes only. It covers the original Coronavirus (COVID-19) Job Retention Scheme (CJRS), first unveiled by the government on 20 March 2020, which applied from 1 March to 30 June 2020. For information on: the extended CJRS operating between 1 May and 30 September 2021, see Practice Note: Coronavirus Job Retention Scheme (extended version 1 May to 30 September 2021) [Archived] the extended CJRS in effect from 1 November 2020 to 30 April 2021, see Practice Note: Coronavirus Job Retention Scheme (extended version 1 November 2020 to 30 April 2021) [Archived] the revised CJRS running from 1 July to 31 October 2020, see Practice Note: Coronavirus Job Retention Scheme (extended version 1 July to 31 October 2020) [Archived] The CJRS was a temporary initiative, originally intended to run for three months from 1 March 2020. On 17 April 2020, HM Treasury announced an extension to 30 June,...

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UK PARLIAMENT ACTS
Financial Services and Markets Act 2000 (2000 c 8)

Financial Services and Markets Act 20002000 CHAPTER 8An Act to make provision about the regulation of financial services and markets; to provide for the transfer of certain statutory functions relating to building societies, friendly societies, industrial and provident societies and certain other mutual societies; and for connected purposes.[14th June 2000]BE IT ENACTED by the Queen's most Excellent Majesty, by and with the advice and consent of the Lords Spiritual and Temporal, and Commons, in this present Parliament assembled, and by the authority of the same, as follows:—Part I . . .1 . . .. . .2 . . .. . .3 . . .[3A . . .]4 . . .5 . . .6 . . .[. . .][6A . . .]. . .7 . . .. . .8 . . .9 . . .10 . . .11 . . .. . .12 . . .13 . . .. . .14 . . .15 . . .16 . . .17 . . .18 . . .[Part 1A The Regulators][Chapter 1 The Financial Conduct Authority][The Financial Conduct Authority][1A The Financial Conduct Authority][The FCA's general duties][1B The FCA's general duties][1C The consumer protection objective][1D The integrity objective][1E The competition objective][Interpretation of terms used in relation to FCA's general duties][1F Meaning of “relevant markets” in strategic objective][1G Meaning of “consumer”][1H Further interpretative provisions for sections 1B to 1G][1I Meaning of “the UK financial system”][Modifications applying if core activity not regulated by PRA][1IA Modifications applying if core activity not regulated by PRA][Power to amend objectives][1J Power to amend objectives][Recommendations][1JA Recommendations by Treasury in...