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The FCA's 23 October announcement describes restrictions on six Annex 1 lenders. It does not mean that every restriction started that day. For a borrower, the useful question is narrower: what can the exact legal entity do with the transaction now being proposed? [C1]
Before relying on a further advance or changing an existing payment, put the lender's identity, the relevant notice and your own agreement beside each other. A news headline cannot settle those three records. This article explains a verification method, not an instruction to stop paying or a finding about your particular facility.
Separate registration from the permission you need
Annex 1 registration concerns supervision under the Money Laundering Regulations. The FCA says the firms covered by its announcement are not authorised or subject to its wider regulation. Registration is therefore a different statement from authorisation for a particular service. [C2]
A business name on a website is a starting point, not the completed check. Record the legal entity named on the offer and the entity named in any restriction. Keep a trading name in a separate field. If they differ, ask the provider to explain the relationship in writing before treating a search result as an answer about your contract.
The FCA's Firm Checker helps consumers check authorisation and permissions. Its guidance also describes omissions, including products offered only to firms or professionals, and points to the Financial Services Register for further information. An empty or incomplete consumer-tool result is not, by itself, a legal classification of a business transaction. [C3]
Match the notice to the proposed action
The announcement distinguishes new business, extensions of credit and, for some firms, restrictions on receiving payments. It identifies different action dates and conditions. Do not turn those summaries into one instruction for all customers. [C4]
Use a three-row note. In the first row, describe the action: a new application, an undrawn advance, a renewal, a repayment or a change of payment account. In the second, record the current document that addresses that action. In the third, write the unanswered question and who must answer it. A blank second row is a reason to seek confirmation, not permission to invent a rule.
A useful question is specific: does the restriction permit the advance described in the attached offer, and which current provision supports that answer? Save the reply with its date. A general statement that the firm is registered does not answer whether a particular transaction is permitted.
Keep repayment questions separate from new borrowing
A restriction on accepting business does not tell you whether an existing debt has disappeared. Equally, a summary mentioning payment restrictions does not provide verified replacement bank details. This explainer has not examined individual contracts, notices or payment instructions, so it does not determine what any customer owes or should pay today.
If a payment is approaching, raise that exact question through a contact route independently checked against official information and your existing records. Ask for the relevant notice and a written explanation of the required action. Do not send money to a changed account merely because a message repeats an accurate regulatory headline.
Keep the original instruction, the proposed change and your verification record together. If the explanation remains unclear, obtain appropriate independent help for the contract before acting on an assumption. This is particularly important where a guarantee, security or another person is involved.
Do not spend an unconfirmed advance twice
Consider an illustrative business expecting a £12,000 advance before a £9,000 supplier payment. These are invented planning inputs, not figures about an affected lender or customer. If the advance has not been confirmed as available, subtracting £9,000 from £12,000 creates a £3,000 paper remainder; it does not create spendable cash.
Keep the supplier obligation and the financing assumption in different columns. Ask when the borrowing becomes an actual available balance, what conditions remain and what happens if that date slips. A useful alternative may be a smaller purchase, a supplier discussion or waiting. Another rapid application is not automatically the answer.
For personal borrowing, the same distinction is between money expected and money actually available. Avoid committing an assumed advance to an expense until the provider has answered the relevant transaction question. This does not predict rejection, delay or approval.
Check protection as a separate question
The FCA says Firm Checker cannot confirm that FSCS or Financial Ombudsman protection will definitely apply. The relevant product and circumstances still matter. Do not attach a protection promise to a registration number or an authorisation search alone. [C5]
End with one short evidence pack: exact contracting entity, dated official notice, the action you need to take and the provider's written answer. Keep unresolved matters visibly unresolved. Before a new commitment, settle the missing permission or availability question; before changing an existing payment, verify the actual instruction that applies to your agreement.
For related decisions, Check business loan rejection reasons; Separate business data from an offer; Compare UK business funding structures. Continue with the borrowing decision guides.
From comparison to calculation
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Open the free toolkitPrimary sources and product pages
- Financial Conduct Authority: Restrictions on six Annex1 firms (checked 2026-10-24)
- Financial Conduct Authority: Firm Checker and its limitations (checked 2026-10-24)
Product details last checked Oct 24, 2026; next scheduled review Nov 23, 2026. This UK-focused guide is educational information, not individualized financial, legal or tax advice. Product terms, offers and eligibility can change.