CurveBlock
The Financial Conduct Authority (FCA) regulates firms that carry on regulated activities in the UK financial markets. For platforms that facilitate property investment, the FCA perimeter determines whether permissions are required: activities such as operating a collective investment scheme, arranging regulated mortgages, or issuing electronic money can trigger authorisation. Platforms must consider whether their products constitute regulated securities, collective investment schemes or investments that attract the full range of FCA rules.
Where FCA authorisation is required, firms are subject to detailed conduct requirements including prudential standards, governance and senior management responsibilities, client asset and money rules, disclosure and suitability obligations, financial promotions regulation and anti-money laundering controls. The client money and custody rules (CASS) are especially relevant where platforms hold investor funds or manage pooled accounts. Consumer protection is a core priority: clear, fair and not misleading communications and appropriate suitability or appropriateness assessments are required for retail investors.
Compliance programmes must also address operational resilience, outsourcing, transaction reporting and ongoing regulatory reporting. The FCA has published guidance and thematic reviews on new models of investment intermediation, crowdfunding and digital investment services; firms should align product design and marketing with those expectations. Where platforms enable secondary trading or novel custody arrangements, additional rules on transparency, market abuse and listing may apply depending on instrument design.
Understanding the FCA framework early in product design reduces regulatory friction and supports appropriate consumer protection. Legal and regulatory advice is essential to determine whether a given platform model requires permission, what permissions are necessary and how to implement effective governance and compliance systems under the FCA regime.