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DETAILED RESEARCH · EVIDENCE & LIMITS INCLUDED

CNI Northern Ireland

C_NI · pass-01Captured 2026-10-2626 tables · 50 claim records · 36 source recordsScoped coordinator review completed

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C_NI PASS-01 — Northern Ireland

Independent provider-classification and authorisation gateway

Narrow investigation completed with identified evidence gaps Not accepted as a country dossier

Research baseline: 22 October 2026, America/Los_Angeles. Actual primary-source access: 26 October 2026 — Pacific date, UTC date and Northern Ireland local date. Exact access times were not recorded. Jurisdiction: Northern Ireland, using UK-wide law only where it applies to Northern Ireland.

Decision: A commercial business that negotiates repayments or advises Northern Ireland borrowers about debts under credit agreements will ordinarily need to test the UK Financial Conduct Authority (FCA) regulated-activity and permission framework. But there is no single statutory licence covering all services marketed as “debt help.” Classification depends on what the business actually does, which debt and person are involved, whose side it represents, whether it acts by way of business, where the activity occurs, and whether a precisely defined exclusion or permitted capacity applies.

Separately, Northern Ireland has its own legal authority for individual voluntary arrangements (IVAs), debt relief orders (DROs), bankruptcy and insolvency practitioners. FCA authorisation alone does not make a firm an NI IVA nominee, DRO approved intermediary or bankruptcy officeholder. Nor does an NI insolvency-practitioner authorisation automatically permit an unrelated commercial debt-management business. [C001–C004, C031–C039] legislation.gov.uk+3

This pass does not determine whether a particular provider is lawful, whether a debt is enforceable, or whether a settlement would succeed.

A. Operative paid-service perimeter

The relevant UK framework is the Financial Services and Markets Act 2000 (FSMA), particularly sections 19 and 22, and the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (RAO). FCA Handbook PERG explains the regulator's interpretation; an R-marked Handbook rule binds within its stated application, whereas G-marked guidance does not create a new statutory activity. The consumer-credit transfer began operating substantively on 1 April 2014. [C001, C009] PERG 2 Authorisation and regulated activities+2

Actual service or feature	Operative test	Preliminary classification, including adverse branch	Claims
Negotiating lower balances or repayment terms for a borrower	RAO 39D(1): negotiating with lender on borrower’s behalf concerning discharge of a credit-agreement debt, taking over discharge obligations for payments, or analogous liquidation activity	Potential debt adjusting. An agreed lump-sum settlement is not necessarily outside the activity simply because no monthly debt-management plan exists. Check precise exclusions.	C002, C016
Similar negotiation for a hirer	RAO 39D(2); underlying consumer-hire agreement	Also potentially debt adjusting, although the product is hire rather than a loan.	C002
Advising a borrower to pay, compromise or otherwise liquidate a particular credit debt	RAO 39E(1)	Potential debt counselling even without negotiations, custody of funds, or a signed plan. A free first meeting does not, by itself, settle the “by way of business” inquiry.	C003, C009
Advising a hirer about a specific consumer-hire debt	RAO 39E(2)	Potential debt counselling, separately tested.	C003
General budgeting, factual explanations or an impersonal educational article	Advice about liquidation of a specified borrower’s covered debt? See FCA PERG 17	May be outside 39E if genuinely general information. Personalized selection of a debt strategy can change the answer. “Educational software” is not itself an exemption.	C043
Collecting debts for creditors	RAO 39F and exclusions	Debt collecting is a distinct creditor-side activity; not synonymous with borrower-side 39D. Applicable debt type, creditor status, and exclusions matter.	C004, C016
Exercising or enforcing a lender’s/owner’s rights on its behalf	RAO 39G	Potential debt administration. Merely administering a borrower’s repayment budget is not automatically 39G.	C005
Referring someone to a consolidation loan or presenting a new credit product	RAO 36A, depending on the introduction, borrower, intended agreement, and exemptions	Potential credit broking. A referral solely to obtain existing-debt advice is not automatically credit broking.	C006
Helping correct credit-report information	RAO 89A credit-information services	A separate possible regulated activity; the exact acts and exceptions must be established.	C007
Agreeing to provide one of the regulated services later	RAO 64 where applicable	An agreement to perform a covered regulated activity can itself require analysis.	C008
Holding or forwarding debtor payments	RAO debt activities plus Payment Services Regulations 2017, if applicable	Payment-service authorisation is not automatic for an ordinary ancillary debt-management-plan distribution; an independently operated money-remittance business may cross another gateway.	C026–C027

The first four rows follow the distinct statutory verbs in RAO articles 39D–39G; they cannot be merged into one debt-negotiator licence category. [C002–C005] legislation.gov.uk+2

Debtor, debt and agreement branches

Branch	Result at this gateway	Missing fact that could change it
Individual borrowing personally	Normally the clearest potential credit-agreement borrower within articles 39D/39E. Not every individual debt is a credit-agreement debt. [C011–C012]	Original contract, creditor identity, debt source and advice actually delivered
Sole trader	May be an “individual” borrower notwithstanding business purpose. A business-purpose exemption from lender regulation under article 60C is not automatically an exemption from 39D/39E, whose wording uses “credit agreement.” [C011–C013, C049]	Whether borrower is individual; loan amount, business purpose, date and nature of agreement
Small partnership/unincorporated organisation	The statutory definition of relevant recipient of credit can include a partnership of two or three persons, and specified small unincorporated bodies; it does not mean every partnership. [C011]	Constitution, partners, borrower named, whether relevant statutory definition met
Incorporated company owing its own trading debt	Company borrowing ordinarily does not satisfy the article 60B individual/relevant-recipient formulation. Do not infer an FCA 39D/39E licence is required for that corporate debt solely from this category. [C011–C012]	Is a human also borrower, guarantor or party to a separate credit agreement? Other regulated activity?
Joint borrowers	Each person legally designated borrower may trigger the borrower-facing test. [C014]	Signed agreement and allocation of contractual obligations
Guarantor or family member paying for someone else	Status as payer or guarantor does not automatically make that person the statutory borrower receiving 39E advice. Conversely, an adviser representing the actual borrower may be conducting 39D. [C014]	Guarantee, borrower identity, agency and advice recipient
Personal secured loan	Security alone does not remove the debt from analysis. Mortgage/home-finance overlaps and RAO 39J require separate classification. [C015]	Land security, first/second charge, mortgage-regulated status and loan terms
Hire purchase/consumer hire	Examine both credit and consumer-hire limbs; distinguish owner’s rights, hirer’s debt and any regulated hire exceptions. [C002–C005]	Hire agreement, owner, hirer and activity
Credit agreement exempt from the lender’s Part 14A regime	RAO 60B(3) defines “credit agreement” separately from “regulated credit agreement”; 39D/E use the former. It is therefore unsafe to equate exempt agreement with unregulated debt advice. [C012–C013]	Specific exemption, 39H/39J/other exclusions, agreement date
Rent arrears, rates, income tax, fines, utilities, support arrears or ordinary trade invoices	No automatic 39D/39E classification solely from these debt labels. Other UK/local legal gateways could still be relevant. [C012, C050]	Did any obligation actually arise under a covered credit/hire agreement, or is there another regulated transaction?
Mixed debts	Classification is activity-by-activity and debt-by-debt. One credit-card debt may make a portion of a proposed paid service regulated even where accompanying tax/rent advice is not 39E. [C003, C012]	Schedule matching each obligation to its governing instrument

Important distinction: In RAO article 60C(3), credit exceeding £25,000 and wholly or predominantly for the borrower's business may make that credit agreement exempt for the lending-activity chapter. The associated declaration creates a rebuttable presumption under article 60C(5)–(6), not an all-purpose debt-advice exemption. The credit agreement versus regulated credit agreement distinction must be maintained. [C013, C049] legislation.gov.uk

B. Actor-role and exclusion matrix

Actor or asserted status	Actual legal route or exclusion	What is not established	Claims
Paid private settlement negotiator	FCA Part 4A permissions for relevant RAO activities unless an actual exclusion/exemption applies	A Companies House or ordinary business registration is not permission.	C001–C003, C023
Paid DMP operator	Usually investigate debt adjusting and counselling, precise FCA permission and any DMP restriction; CONC 10 resources if within application	“Authorised” without corresponding specific activity and restrictions is not enough.	C023–C024
Charity/not-for-profit debt adviser	The Carrying on Regulated Activities by Way of Business Order 2001, art. 3E, expressly treats qualifying not-for-profit bodies undertaking specified non-occasional debt adjusting, counselling and credit-information services as operating by way of business. Constitution/public-purpose/no-distribution predicates matter.	“Free,” “charity” or “no debtor fee” is not a blanket FCA exemption. [C010, C017]	C010, C017
Infrequent nonprofit assistance	Article 3E(2) excludes activities carried on only occasionally from that deeming provision	This is not a declaration that every occasional case is free of all other statutory tests.	C010
NI district council acting itself	RAO 72G local-authority exclusion applicable to articles 39D–39G; RAO art. 3 defines local authority for NI as a district council	Neither every “government-funded” organisation nor every council affiliate is automatically within the precise statutory exclusion.	C018
Public advice department or agency that is not an NI district council	Identify the exact statutory personality, function and any specific exemption	“Public sector” does not itself equal RAO 72G.	C018
NI solicitor acting in litigation/advocacy	RAO 39K excludes relevant barristers and solicitors acting in specifically described advocacy/litigation capacities	General non-litigious commercial debt settlement is not universally excluded merely by a solicitor practising certificate.	C019
Solicitor/accountant firm providing incidental regulated services	FSMA Part XX, especially s.327, and designated-body rules under ss.326/332 may provide exempt professional firm status if all conditions hold: professional membership/control, complementary/incidental activity, approved body rules, treatment of outside reward, and any restrictions/directions.	A professional title alone is insufficient. Law Society NI's role as an FSMA designated professional body must not be confused with its former NI insolvency-practitioner recognising role.	C020, C034, C047
Creditor collecting or restructuring its own claim	Specific RAO 39H lender/owner/supplier exclusions for certain 39D–39G acts, alongside lender-rights rules under 60B and exceptions such as the 39H(1A) debt-collecting qualification	A third-party collector or independent debt purchaser cannot rely on a broad “creditor exemption” without testing the legal capacity.	C016
Debt buyer, servicing firm or collection agency	Examine rights acquired, whether acting for lender/owner, article 39F, 39G, 60B(2) and 39H conditions	Creditor-side activity does not prove borrower-side counselling permission.	C004–C005, C016
Pure information publisher or software vendor	No activity-based exemption merely because delivery is electronic. Examine functionality, influence on a particular debtor’s decision, operator and benefit.	“AI,” “self-service” or “referral website” is not an FCA-authorised class.	C006–C008, C043
Payment-only distributor	First distinguish ancillary distributions under a DMP from payment service independently carried on as a business under the 2017 Payment Services Regulations	Neither universal payment-service licensing nor universal exclusion can be inferred.	C026–C027
Statutory insolvency practitioner	RAO 72H excludes certain activities while acting as an insolvency practitioner; a narrower prospective-appointment exclusion covers 39D, 39E and 89A in reasonable contemplation of appointment.	The same practitioner's separate retail debt-negotiation venture cannot use a general lifelong exclusion.	C021, C047
Appointed representative (AR)	FSMA s.39 and FCA SUP 12 where an eligible activity is covered by a principal's agreement and corresponding permission, with principal responsibility	AR status for an unrelated permission does not cover debt adjusting. Verify scope and FCA listing.	C022

The not-for-profit and professional boundaries are especially consequential: the former may be positively treated as carrying on a business, while the latter is a conditional capacity exemption rather than immunity for a profession. [C010, C020] SI20130726rvsdRAONo2130725+2

C. Permission, registration and gateway safeguards

Who must have what?

Direct FCA authorisation: The legal entity undertaking an in-scope regulated activity ordinarily needs FCA Part 4A authorisation with that particular permission, absent a valid exemption. A permission to collect creditor debts or broker credit is not, on its face, permission to conduct every debtor-side debt-management service. [C001, C023]
Full versus limited permission: These are meaningful FCA classifications with restricted activities. FEES 3 distinguishes a non-DMP/limited-description debt-adjusting or debt-counselling application from a broader debt-management application. The application-fee category is not itself a legal permission. [C023, C025]
Appointed representative: Check the authorised principal, the AR contract/scope and the regulated activity the arrangement legally covers. It is not a stand-alone FCA authorisation for all services. [C022]
Exempt professional firm: Verify the qualifying firm, designated professional body, relevant body rules and actual restricted capacity under FSMA Part XX. This is neither a Part 4A licence nor unrestricted authority. [C020]
Statutory NI insolvency role: Verify individual insolvency-practitioner authorisation and case appointment, or DRO intermediary approval through a designated competent authority. The supervising government department is the NI Department for the Economy, including its Insolvency Service functions—not the FCA for the local statutory appointment. [C031–C037]
Separately conducted remittance: If payment transmission is independently provided within the Payment Services Regulations 2017, investigate FCA-authorised payment institution, small-payment-institution registration or another actual statutory category. Merely handling DMP instalments ancillary to debt management ordinarily does not itself establish this activity in the FCA's stated view. [C026–C027] PERG 15.2 General

Gateway fitness and financial safeguards: FCA authorisation involves threshold conditions and responsible governance/competence assessment. For firms to which CONC 10 applies, ongoing solvency and specified prudential resources are actual binding R rules, not a guaranteed compensation account. It applies to debt management firms, and also a not-for-profit debt advice body holding or projecting at least £1 million client money at the stated rolling 12-month threshold; qualifying primarily professional firms have a specific exception. [C024, C041] handbook.fca.org.uk

Sourced gateway example	Computation or amount	Crucial limit
2026 FCA Part 4A application fee, FEES 3 Annex 1/1A	CC2 debt adjusting/counselling in the restricted category 3: £1,130; broader category 6: £11,260 (Annex 1A effective 2 July 2026)	Only if the applicant fits that category. No customer fee is stated or implied; multiple-activity and special-classification rules may alter an application. [C025]
CONC 10 prudential resources, £2 million relevant debts under management	£2,000,000 × 0.25% = £5,000; compare £5,000 floor ⇒ £5,000	Applies only to covered firms/debts; not £5,000 held for each customer. [C024]
CONC 10 prudential resources, £10 million relevant debts under management	First £5m × 0.25% = £12,500; next £5m × 0.15% = £7,500; total £20,000	If another regulated activity imposes higher prudential resources, use the higher requirement. [C024]
NI insolvency practitioner bond, general penalty sum	2025 amendment substitutes £750,000 for £250,000	Transitional saving: qualifying bond issued and practitioner appointed before 1 January 2027 can remain under prior terms. Fraud/dishonesty bond cover—not a universal debtor refund or guarantee. [C040]

The FCA fee schedule and CONC amounts are current Handbook values in the sources actually read. The NI bond is governed by its distinct 2025 statutory instrument, operative 9 December 2025, including its express 2027 saving. handbook.fca.org.uk+4

Historic transition: The 2013 consumer-credit transfer included interim permissions and a narrow grandfathering rule for certain not-for-profit group-licence bodies; it is not a general present-day entitlement inferred from a former Office of Fair Trading credit licence. [C009, C046] The 2011 NI DRO intermediary regulations also contain pre-2014 references to consumer-credit licences: those provisions cannot responsibly be translated into a definitive 2026 FCA licensing requirement without resolving amendment, supersession and interpretation. [C036; unresolved U03]

D. Territorial and activity-location boundary

For the relevant UK-wide FSMA framework, Northern Ireland is within the UK. FCA PERG 2.4 addresses whether activity is carried on in the UK, including circumstances where the provider is based elsewhere. A Northern Ireland debtor's address, a non-UK website domain or a firm's location, taken in isolation, is not a complete territorial legal test. [C028] handbook.fca.org.uk

Hypothetical nexus	Narrow decision
NI firm advising NI borrower by telephone	Test UK regulated activity and precise RAO permission/exclusion; medium is not a safe harbour.
Firm elsewhere in the UK soliciting NI customers	UK-wide FCA perimeter may apply, but local NI statutory solution roles remain a separate legal test.
Overseas firm with no NI premises selling paid, tailored advice into NI	Do not infer “outside FCA jurisdiction.” Assess where conduct occurs, UK connection, actual FSMA territorial construction and any specific exemption. RAO article 72 overseas-person exclusions are not a blanket exclusion from debtor-side 39D/39E.
NI company advising debtors abroad	The NI establishment can supply a UK nexus; a foreign client's residence does not by itself cancel the UK test. Foreign local licensing is deferred to A098.
Offshore marketing affiliate or call centre	Identify which legal person markets, advises, refers, negotiates, receives commission or money, and who is principal/agent. Treat each activity and jurisdictional connection independently.

No conclusion about foreign recognition, creditor law, judgment enforceability, currency or overseas insolvency is adopted in this pass. [C028, C050]

E. Read-only official verification workflow

This is the hypothetical method a consumer would use. No actual person, provider, firm registration or insolvency case was queried.

Step	Document/fact to obtain hypothetically	Official comparison and decision
1. Establish entity	Exact legal name, legal form, any trading names, registered address and the party signing the engagement	Do not check a brand name alone against a regulator entry.
2. Classify conduct	Who gives advice, negotiates, proposes plan, receives commission, collects money, introduces credit or claims to be an officeholder	Map to RAO 39D/E/F/G, 36A, 89A, or payments/NI insolvency gateway as appropriate. [C002–C008]
3. Match debt and recipient	Agreements; named borrower/hirer; guarantor role; original purpose; secured status; debt-by-debt schedule	Confirm the legal subject matter before interpreting “permission.” [C011–C015]
4. Verify FCA category	FCA Financial Services Register and FCA Firm Checker	Inspect status, legal entity, permission wording, restrictions, effective periods and, for ARs, principal and covered capacity. Do not treat simple listing as unrestricted approval. [C030, C044]
5. Verify NI IVA/bankruptcy practitioner status	Individual's claimed RPB, licence scope and actual statutory appointment	Use the NI Department for the Economy's insolvency practitioner directory, understanding directory completeness/opt-in limitations, and the appropriate authorising body's status evidence. [C032–C035]
6. Verify NI DRO adviser capacity	Claimed approved intermediary, its competent authority, and current approval; not merely charity employment	Compare against the Department's designated competent authorities list; the authority's approval of the individual is the further question. [C036]
7. Verify cash-flow category	Whether consumer pays creditor directly, through the debt firm, through a third-party payment provider, or via standalone money remittance	Determine the actual payer/payee/service and if a separate payment-services permission/registration must be checked. [C026–C027]
8. Keep conclusion conditional	Capacity, permission, exclusions and relevant dates	A regulator listing proves neither creditor agreement to settle, contractual fairness, lawful customer fees, release of debt, nor settlement outcome. [C044]

F. Northern Ireland's separate statutory-practitioner boundary

Mechanism/capacity	NI source and decision maker	Gateway distinction and currentness
Private voluntary repayment/settlement negotiation	Ordinary debtor-creditor negotiation; FSMA/RAO only if covered activities are undertaken	No private “settlement proposal” becomes a statutory NI IVA simply by being called an arrangement. A firm may need FCA permission but not NI IVA nominee status merely to negotiate privately. [C048]
Individual voluntary arrangement (IVA)	Insolvency (Northern Ireland) Order 1989, Part VIII, Chapter II; NI High Court and qualified nominee/supervisor according to relevant procedure	An appropriately authorised individual insolvency practitioner is the operative professional route. The older alternative authorised-nominee wording and Article 348A were repealed by the Insolvency (Amendment) Act (Northern Ireland) 2016, Schedule 3/4. Do not resurrect them from an older consolidation. [C031–C032]
Debt relief order (DRO)	NI 1989 Order Part VIIA as introduced by the Debt Relief Act (Northern Ireland) 2010: Official Receiver determines order; Article 208U approved intermediary assists in applications under approval from a Department-designated competent authority	An organisation's designation does not by itself mean every staff member is individually approved. There is an express Article 208U restriction on intermediary charges connected with the application; the wider consumer fee dossier is deferred. [C036–C037]
Bankruptcy	NI 1989 Order bankruptcy provisions; NI High Court, Official Receiver and appropriately qualified statutory officeholder capacities	No ordinary private debt counsellor becomes a trustee/Official Receiver. Full court petition and trustee powers are deferred. [C038]
Fast-track voluntary arrangements	NI 2026 Act s.93, commenced by S.R. 2026 No.180, art.2(2)(n)	Repealed for new cases from 16 October 2026, but s.93(6) expressly preserves cases in which the debtor supplied the specified documents to the Official Receiver before commencement. An older government or statutory index may still display the former route. [C039]
Recognised professional body (RPB) authorising an NI insolvency practitioner	NI 1989 Order articles 349/349A/350, as substantially amended in 2016; Department for the Economy recognises/oversees bodies; authorised individual, potentially full or individual-only/companies-only partial authorisation	Check current body recognition and the specific individual's authorisation and case capacity. A generic accountant/solicitor title or RPB trade membership does not suffice. [C032–C035]

Two corrections are essential:

Law Society of Northern Ireland: its NI insolvency-practitioner RPB recognition was revoked 5 November 2025 by S.R. 2025 No.170. This says nothing by itself about the separately designated FSMA Part XX professional body function. [C020, C034] legislation.gov.uk+1
Chartered Accountants Ireland: the NI Department says its NI insolvency-practitioner RPB recognition ceased 19 February 2025. Current recognition cannot be inferred from a historical list bearing its name. [C035] Department for the Economy

Currency hold: The full up-to-the-minute consolidated 1989 Order returned unsupported XHTML/timeouts through the public reader. The operative 2010, 2016, 2025 and October 2026 amending enactments were read directly, but the entire consolidated NI officeholder/recognising-body schedule has not been independently certified. This prevents a categorical assertion that every entry on an older directory is current. The source and coverage registers below preserve that exact limitation.

G. Eight bounded actor/activity scenarios

These are constructed hypotheticals, not real consumer, provider, creditor or case determinations. None assumes an agreement, licence, approval or debt result not specified.

Scenario and known facts	Actual test / provisional result	Missing facts and adverse branch	Decision maker, documents, next read-only check
G1. Paid card settlement. An NI company charges customers to telephone credit-card lenders and seek reduced settlements for the cardholders.	Strong potential 39D debt adjusting; any borrower-specific repayment recommendations add 39E. [C002–C003]	Legal borrower, nature of each card debt, full service and any exclusion. “One-off settlement” does not alone defeat 39D.	FCA gateway. Engagement terms, service scripts, agreements, company identity; compare FCA status, 39D/39E permissions and restrictions.
G2. Free charity debt clinic. An NI charity regularly advises individuals about their named card and hire debts without billing those individuals.	Articles 39D/E if acts occur; business-order art.3E may deem non-occasional covered charity activity by way of business. [C003, C010]	Charity constitution, legal entity, how regularly it advises, actual regulatory route. No customer fee is not exemption.	FCA or valid exemption route. Constitution, funding/benefit, case workflow, exact authorisation/exempt-capacity evidence; check FCA record or governing exemption.
G3. Solicitor-led negotiations. A practising NI solicitor proposes a non-litigious telephone debt-settlement service as a stand-alone paid offering.	RAO 39K advocacy/litigation exclusion cannot automatically be applied. Test FSMA s.327 professional-firm conditions or appropriate FCA permission. [C019–C020]	Are services genuinely litigation/advocacy or incidental to supervised professional work? Separate remuneration, advertising, body rules, entity structure.	Law Society NI designated professional-body capacity and/or FCA. Practising status, firm structure, activity descriptions, remuneration agreement; compare actual exempt-professional conditions.
G4. Insolvency practitioner also sells private DMPs. An NI-authorised individual acts as IVA supervisor in one matter but separately markets monthly repayment negotiation to unrelated people.	RAO 72H applies to acts in IP capacity, not automatically to the separate DMP business. [C021, C047]	Which entity contracts, appointments, case files and acts are in which capacity?	NI authorising RPB for statutory office; FCA for separate regulated service. Licence/appointment documents and separate DMP engagements; check both gateways distinctly.
G5. “DRO approved” staff member. A debt charity appears on an NI competent-authority list, and an employee offers to file a DRO.	Article 208U requires a specifically approved individual through a designated competent authority. [C036]	Whether employee is approved, whether approval remains effective, capacity and restrictions. Organisation listing alone insufficient.	NI designated competent authority / Official Receiver. Organisation designation and individual's approval evidence; use published authority list without making any actual-person query.
G6. Outside-UK app selling NI debt recommendations. A foreign website accepts an NI customer's debt figures, suggests settlements and takes a referral payment.	FCA PERG 17 helps distinguish factual information from debt counselling; FSMA UK territorial nexus remains fact-sensitive. [C006, C028, C043]	Provider establishment, recipient, where personalised advice occurs, affiliate roles, fee/benefit, debt source. “Foreign site” alone not exclusion.	FCA perimeter plus deferred foreign-law analysis. Product demonstration, terms, referral agreements, operator chart and data flow; match each act to permissions.
G7. Debt buyer enforces acquired loans. A company buys outstanding borrower receivables and pursues payments for itself, without taking customer debt-advice mandates.	Examine 39H, 39F/G, 60B(2) and acquired lender rights; not automatically 39D. [C004–C005, C016]	Legal assignment, ownership vs servicing, covered agreement, whether collector acts for itself/another.	FCA. Assignment and servicing contracts, product samples, collector's activities; compare permission for exercising lender rights/collecting/administration.
G8. Payment distributor. A processor receives customers’ instalments and sends them to creditors; it does not advise or negotiate.	Determine whether it independently provides regulated money remittance under the 2017 Regulations or merely performs ancillary DMP distributions under FCA PERG 15.2 Q9. [C026–C027]	Who holds funds, for whose account, source of instructions, business model, contractual status and any separate payment service.	FCA payments gateway where triggered. Flow-of-funds schematic, user contract and processing arrangement; check appropriate payment-institution/agent category rather than assuming a debt-adjusting licence.

Enforcement consequence, bounded

FSMA s.19 prohibits carrying on a regulated activity in the UK unless authorised or exempt; s.20 addresses authorised firms outside their permission; s.23 sets criminal consequences with its own elements and applicable defences. FCA PERG describes the prohibition and penalties. Neither suspicion of an unauthorised provider nor even an authorisation offence automatically establishes that the original creditor debt, agreement or judgment is cancelled or that a consumer receives a private monetary award. The separate FSMA agreement-enforceability provisions, remedies, procedures and defences are later work. [C001, C029] legislation.gov.uk+1

Publication and reuse rules arising from this pass

A useful consumer-facing NI gateway question should ask:

“Are you being offered help negotiating an existing debt, general information, a repayment plan, creditor collection, an insolvency arrangement, or a DRO application—and who is legally providing each service?”

A subsequent question should ask for debt type and actual borrower/guarantor status before showing any suggested FCA permission or NI practitioner class. Where a provider invokes charity, solicitor, accountant, official receiver, insolvency practitioner or appointed-representative status, the explanation must disclose the restricted capacity being claimed.

Hold before publication: Do not publish a definitive “all debt companies in NI must be FCA licensed,” “charities are unregulated,” “all insolvency practitioners can negotiate any debt,” “the Law Society of NI still licenses NI insolvency practitioners,” or “fast-track IVA applications remain open” statement. All are contradicted or materially qualified by the primary evidence. [C010, C020–C021, C034, C039]

Complete visible primary-source register

Conventions:

Each S identifier is unique within this pass. All records below were accessed or attempted 26 October 2026.
B means the identified substantive body or PDF text was actually returned and read; I means source/index or discovery only; F means the specified fetch failed. Index text is not treated as a statutory body read.
For PDF sources, P0, P1, … are zero-based PDF indices, distinct from printed document page numbers. If no reliable printed pagination exists, that is stated.
A legislation.gov.uk point-in-time URL records the date selected in the URL, not a certification of all subsequent amendments. A current FCA Handbook interface and its rule dates are noted independently.
All source URLs are given literally and directly. The linked document is the issuer's public source, not another country's research report.

UK-wide FSMA, regulated activities and FCA perimeter

ID / status	Issuer, direct official URL and exact portion read	Version/effect; actor, debt and jurisdiction limits
S001 B	UK Parliament, Financial Services and Markets Act 2000, original enacted PDF; ss.19–23, 26–29, 39–40, 326–327 and 332. PDF P27–P32, corresponding original printed pp.8–13 for main prohibitions/remedies; P36–P37, printed pp.17–18 for representative/application route. `https://www.legislation.gov.uk/ukpga/2000/8/pdfs/ukpga_20000008_en.pdf`	As enacted 2000 only, not a reliable modern consolidation. UK including NI, persons conducting regulated activities. Used with current FCA guidance/amending law; original statutory wording is not asserted unchanged in all respects. legislation.gov.uk
S002 B	FCA, PERG 2—Authorisation and regulated activities, especially 2.2 prohibition/permission and 2.4, 2.8–2.11 scope/exemption context. `https://handbook.fca.org.uk/handbook/perg2?timeline=true`	Current FCA Handbook display accessed 26 Oct 2026; relevant interface shows changes through 16 Sept 2026. Guidance (G), UK regulated activities and NI nexus, not a statutory substitute. PERG 2 Authorisation and regulated activities
S003 B	UK Treasury, Regulated Activities Order 2001, Part II arts.4, 36A, 39D–39L, 60-series references, 64, 72, 72G, 72H, 89A references, detailed exceptions/annotations. `https://www.legislation.gov.uk/uksi/2001/544/part/II/2025-07-15/data.html`	Official 15 July 2025 point-in-time consolidated body. UK except express geographic limits; credit agreements/hire and regulated services. July–Oct 2026 Part II whole-part consolidation was unavailable, so amendment completeness after that date is held. legislation.gov.uk
S004 B	UK Treasury, same RAO, article 3 interpretation, including NI local authority and insolvency-practitioner cross-references. `https://www.legislation.gov.uk/uksi/2001/544/article/3/2026-02-25/data.html`	25 Feb 2026 point-in-time body, UK/NI definition branch; does not certify all changes after selected date. legislation.gov.uk
S005 B	UK Treasury, same RAO Part II Ch.14A, arts.60B and 60C(1)–(8), credit/regulated credit and business-purpose exemptions. `https://www.legislation.gov.uk/uksi/2001/544/part/II/chapter/14A/crossheading/the-activities/2026-07-15/data.html`	15 July 2026 point-in-time body, individual/relevant recipient of credit; distinguishes borrower and lender permissions from debt-counselling activities. legislation.gov.uk
S006 B	UK Treasury, S.I.2013/1881, Financial Services and Markets Act 2000 (Regulated Activities) (Amendment) (No.2) Order 2013: art.1(2)–(6), arts.3–5, art.13 inserting business-order art.3E, art.60 grandfathering. PDF P0–P3 printed pp.1–4; P31–P32 printed pp.32–33; P68 printed p.69. `https://www.legislation.gov.uk/uksi/2013/1881/pdfs/uksi_20131881_en.pdf`	As-made enactment, central operative date 1 April 2014 subject to preparatory/transitional commencement. Historical group-licence provisions not general 2026 permission. UK including NI. SI20130726rvsdRAONo2130725
S007 B	FCA, PERG 2.3.1–2.3.3 “The business element”; nonprofit art.3E, occasional business and case factors. `https://handbook.fca.org.uk/handbook/perg2/perg2s3`	FCA G, current displayed version last updated 16 Sept 2026, future version indicated for 2027 (not yet operative). UK covered actors. PERG 2.3 The business element
S008 B	FCA, PERG 17.2 basic debt-counselling elements, borrower, particular credit debt and advice. `https://handbook.fca.org.uk/handbook/perg17/perg17s2`	FCA G, current interface viewed; UK including NI, particular credit/hire debt advice. handbook.fca.org.uk
S009 B	FCA, PERG 17 consolidated consumer-credit debt-counselling questions and examples, general information versus borrower-specific assessment. `https://handbook.fca.org.uk/handbook/perg17`	FCA G, 26 Oct 2026 access; UK covered debt advice. Guidance examples cannot settle unspecified software behaviour. PERG 17 Consumer credit debt counselling
S010 B	FCA, PERG 2.4, link between regulated activities and the UK. `https://handbook.fca.org.uk/handbook/perg2/perg2s4?timeline=true`	FCA G, displayed current at access; UK territorial operation, overseas and NI services. No foreign-state licensing certification. handbook.fca.org.uk
S011 B	FCA, SUP 12, appointed representatives: responsibilities, contractual scope, oversight and relevant registration. `https://handbook.fca.org.uk/handbook/sup12`	Current FCA Handbook section as accessed; R/G depending provision. AR/principal route for activities lawfully eligible; UK including NI. SUP 12 Appointed representatives
S012 B	FCA, PROF 2.1.1–2.1.14, FSMA ss.326–329, 332 professional-firm gateway and restrictions. `https://handbook.fca.org.uk/handbook/prof2/prof2s1`	FCA G; display last updated 23 Oct 2025 (subrules have own dates). UK designated professional bodies and regulated incidental services. handbook.fca.org.uk
S013 B	FCA, PROF 2 Annex 1.1, designated bodies including Law Society of Northern Ireland and accountancy bodies. `https://handbook.fca.org.uk/handbook/prof2/prof2s2?timeline=true`	FCA G annex updated 6 July 2006; historic designation list—current applicability also conditional upon statutory/body rule changes. Not the NI insolvency RPB roster. handbook.fca.org.uk
S014 B	FCA, FEES 3 Annex 1, Part 2 activity groups CC1/CC2; Annex 1A pricing categories; FEES 3.2. `https://handbook.fca.org.uk/handbook/fees3`	Binding R fee provisions; Annex 1A last updated 2 July 2026: category 3 £1,130, category 6 £11,260. Application fees only, subject to category/other rules; UK including NI. handbook.fca.org.uk+1
S015 B	FCA, CONC 10.1.1–10.1.6, 10.2.1–10.2.14, prudential-resource application, £1m nonprofit test, formula, £5k minimum, professional exception. `https://handbook.fca.org.uk/handbook/conc10`	Binding R versus marked G. Chapter shows last update 1 July 2014; current interface accessed 26 Oct 2026. Applicable UK debt-management firms including NI; not every debt adviser. handbook.fca.org.uk+1
S016 B	UK Treasury, Payment Services Regulations 2017, regs.2, 4–5; Sch.1 Part 1 para.1(f), Part 2; Sch.3. PDF, P11–P14 printed approximately pp.12–15; P93–P96 printed pp.94–97 for capital/own funds. `https://www.legislation.gov.uk/uksi/2017/752/pdfs/uksi_20170752_en.pdf`	As-made 2017, later changes not comprehensively consolidated here. Payment institutions, stand-alone remittance and exclusions; UK including NI. Not an automatic classification for DMP transfers. legislation.gov.uk
S017 B	FCA, PERG 15.2 Q9, Q11–Q11B, payment activity as a business in its own right, ordinary ancillary DMP examples and dual FSMA/payment capacities. `https://handbook.fca.org.uk/handbook/perg15/perg15s2`	FCA G current accessed page; UK payment-service providers, including NI; fact-sensitive exception, not unconditional authorisation. PERG 15.2 General
S018 B	FCA, Apply to become an electronic money or payment institution, application/registration gateway. `https://www.fca.org.uk/firms/apply-emoney-payment-institution`	FCA official page current accessed 26 Oct; webpage last-updated marker 20 Aug 2026. Payment providers, not every debt firm; procedural costs/details outside narrow pass. FCA
S019 B	FCA, Safeguarding requirements for EMIs and payment institutions, scope of payment-institution safeguards. `https://www.fca.org.uk/firms/emi-payment-institutions-safeguarding-requirements`	FCA official page current at access; includes 2026 material, but no full client-money/safeguarding audit undertaken. UK including NI when payment gateway actually applies. FCA

Northern Ireland statutory solution, officeholder and verification sources

ID / status	Issuer, direct official URL and exact portion	Version/effect; actor, debt and jurisdiction limits
S020 F/I	UK legislation publisher, Insolvency (Northern Ireland) Order 1989, S.I.1989/2405 (N.I.19), attempted full contemporary revision and narrower arts. 3, 208U, 227–236, 348–350. `https://www.legislation.gov.uk/nisi/1989/2405/2026-06-25/data.html`	26 Oct 2026 full-body fetch failed (timeout); separate article pages produced unsupported XHTML. Search-index extracts of 349 and 208U were viewed but not treated as body-read. Historical and subsequently amended text separately supported by S021–S032. This is an explicit current-consolidation gap. Internal Error+2
S021 B	NI Assembly, Insolvency (Amendment) Act (Northern Ireland) 2016, ss.14–17; Schedule 2 transition paras.11–16; Schedule 3 paras.4–15; Schedule 4 repeal of arts.348A/351–354. PDF P13–P17, printed pp.10–14; P40–P44, printed pp.37–41. `https://www.legislation.gov.uk/nia/2016/2/pdfs/nia_20160002_en.pdf`	Enacted 29 Jan 2016; substantive provisions commenced separately, notably 2016 officeholder reform and repeal. NI only; authoritative amended statutory wording, not proof that every provision was effective at Royal Assent. legislation.gov.uk+1
S022 B	NI Assembly, Debt Relief Act (Northern Ireland) 2010, s.1 introducing 1989 Order Part VIIA; arts.208A–208E and 208U, especially intermediary and competent authority. PDF P1–P4 printed pp.1–4; P15–P17 printed pp.15–17. `https://www.legislation.gov.uk/nia/2010/16/pdfs/nia_20100016_en.pdf`	As enacted 2010; commenced by separate instruments, not assumed immediately effective. NI DROs only. Later threshold/qualification amendments not audited in this narrow gateway. Front Cover of Act.doc+1
S023 B	NI Department, Debt Relief Orders (Designation of Competent Authorities) Regulations (Northern Ireland) 2011, regs.2–10: designation, fit/proper body, restricted designation, individual intermediary approval, training/insurance/documents. PDF P0–P5, printed pp.1–6. `https://www.legislation.gov.uk/nisr/2011/15/pdfs/nisr_20110015_en.pdf?wrap=true`	As-made 2011. References to historic consumer-credit licensing require 2014/current-law reconciliation. NI DRO competent authorities and individual intermediaries. N4713_floating.doc+1
S024 B	NI Department for the Economy, Debt Relief Orders, discussion of Official Receiver, approved advisers and agency role, especially page sections “What is a debt relief order?” and “More information.” `https://www.economy-ni.gov.uk/topics/debt-relief-orders`	Live NI agency page accessed 26 Oct 2026; may include newer product eligibility thresholds not adopted in P01. NI public guidance, not a substitute for individual approval. Department for the Economy
S025 B	NI Department for the Economy, List of competent authorities in relation to the debt relief scheme, publication metadata and designated-organisation document link. `https://www.economy-ni.gov.uk/publications/list-competent-authorities-relation-debt-relief-scheme`	Published 26 May 2015, last updated 22 Apr 2024. Page body-read, linked Word attachment not body-read. Thus names/completeness of the current list are not certified. Department for the Economy
S026 B	NI Department for the Economy, S.R.2025 No.170, Insolvency Practitioners (Recognised Professional Bodies) (Revocation of Recognition) (No.2) Order (NI), arts.1–2. PDF P0–P1, printed pp.1–2; explanatory P2, printed p.3. `https://www.legislation.gov.uk/nisr/2025/170/pdfs/nisr_20250170_en.pdf`	Effective 5 Nov 2025; removes Law Society of NI from NI insolvency RPB schedule. Not an FSMA s.326 designation repeal. legislation.gov.uk
S027 B	NI Department for the Economy, Insolvency Service notice—revocation of recognition of the Institute of Chartered Accountants in Ireland as an RPB, paragraphs about art.350N and effective date. `https://www.economy-ni.gov.uk/articles/insolvency-service-notice-revocation-recognition-institute-chartered-accountants-ireland-recognised-professional-body-economy-0`	NI Department notice: 19 Feb 2025 effective; describes move of authorisations. The corresponding S.R.2025 No.19 was not separately body-read, a narrower evidentiary limit. Department for the Economy
S028 B	NI Department for the Economy, Insolvency Service notice—Law Society NI RPB recognition revocation, art.350N notice/reasons. `https://www.economy-ni.gov.uk/publications/insolvency-service-notice-revocation-recognition-law-society-northern-ireland-recognised-professional-body`	Dated 5 Nov 2025; confirms practitioner transition, distinct from FCA designated-professional status. NI specific. Department for the Economy
S029 B	NI Department, Insolvency Practitioners Regulations (Northern Ireland) 2006, especially regs.2, 6–10, 12 and Sch.2 paras.1–3. PDF P2–P5, printed pp.3–6; bond P11–P13, printed pp.12–14. `https://www.legislation.gov.uk/nisr/2006/33/pdfs/nisr_20060033_en.pdf`	As-made 2006, professional fitness/training and original £250k general-bond term; substantially amended after 2006, including S030. Historic officeholder qualification references cannot supersede 2016 reforms. N2491_floating.doc+1
S030 B	NI Department for the Economy, S.R.2025 No.177, Insolvency Practitioners (Amendment and Transitional Provisions) Regulations (NI) 2025, regs.1, 3–6, Sch.2 substituted bond terms. PDF P0–P3, printed pp.1–4. `https://www.legislation.gov.uk/nisr/2025/177/pdfs/nisr_20250177_en.pdf`	Operative 9 Dec 2025 with pre-1 Jan 2027 bond/appointment saving. NI IP fraud/dishonesty security, £750k prospective general penalty sum, not consumer-money guarantee. legislation.gov.uk+1
S031 B	NI Assembly, Insolvency (Amendment) Act (NI) 2026, Part 8, s.93(1)–(6) repeal of fast-track voluntary arrangements and existing-case saving. `https://www.legislation.gov.uk/nia/2026/6/part/8/data.html`	Royal Assent 24 June 2026 is distinct from substantive commencement. NI s.93 commenced 16 Oct 2026 by S032. No PDF pagination for this HTML section. legislation.gov.uk
S032 B	NI Department for the Economy, S.R.2026 No.180, Insolvency (Amendment) (2026 Act) (Commencement No.1 and Transitional Provisions) Order (NI) 2026, arts.2(1)–(2)(n),(s), 3–5. `https://www.legislation.gov.uk/nisr/2026/180/made/data.html`	Made 15 Oct, relevant provisions in force 16 Oct 2026; other provisions expressly future or commenced for preparatory/delegated purposes only. NI, no PDF pages for HTML. legislation.gov.uk
S033 B	FCA, FCA Firm Checker, guidance for confirming permitted financial service identity. `https://www.fca.org.uk/consumers/fca-firm-checker`	Public official guidance accessible 26 Oct 2026; consumer read-only lookup workflow described, not performed. UK including NI. FCA
S034 B	FCA, Financial Services Register, listing types and status/permissions information. `https://www.fca.org.uk/firms/financial-services-register`	Official register guidance accessed 26 Oct 2026. No person/firm record was queried. Registration and authorisation classes are not interchangeable. FCA
S035 B	NI Department for the Economy, Find an insolvency practitioner, official directory search description. `https://www.economy-ni.gov.uk/services/find-insolvency-practitioner`	Live webpage accessed 26 Oct 2026; no search undertaken. Directory results may not by themselves establish officeholding in a particular case. Department for the Economy
S036 B	NI Department for the Economy, Statement of Insolvency Practice 3.1—Individual Voluntary Arrangements, introductory official description of IP as adviser/nominee/supervisor. `https://www.economy-ni.gov.uk/publications/sip-31-individual-voluntary-arrangements`	Page published 1 July 2014; page body read, linked SIP PDF not read. This supports the NI IVA role distinction only; not a full 2026 procedures/conduct statement. Department for the Economy

Register completeness: 36 source records, of which 35 contain directly read source bodies or substantive official webpage text and S020 is explicitly failed/index-only. This is an evidence-access count, not a certification of complete NI legal coverage. S025 and S036 are page-body reads only, not reads of their linked attachments. The 2000, 2006, 2010, 2011, 2013 and 2017 enacted PDFs must be interpreted with their amendments and effective dates; no as-made PDF is presented as an unamended 2026 consolidation.

Atomic claim register

A claim identifier records a particular assertion, not an overall conclusion about an entire country. Confidence refers to whether the cited primary material supports the stated narrow proposition as of the research date:

H: Operative text/current official regulatory explanation directly supports the proposition, subject to its stated predicates.
M: Supported by an actual body read, but a point-in-time consolidation, amendments or case-specific facts constrain reuse.
L/held: A material currentness or source-access gap prevents a definitive conclusion.

FCA perimeter and debtor/debt classification

Claim	Exact assertion; required predicate or exception; consequence	Direct source and pinpoint	Confidence / limit
C001	A person carrying on a regulated activity in the UK needs appropriate authorised or exempt status under FSMA s.19, where the statutory elements apply.	S001 s.19, S002 PERG 2.2, S003 art.4	H; exemptions/territory remain case-specific.
C002	Negotiating discharge of a credit-agreement borrower's debt for that borrower, assuming business conduct and no exclusion, falls within RAO 39D(1); the specified consumer-hire equivalent falls under 39D(2).	S003 art.39D(1)(a)–(c),(2)(a)–(c)	H for activity words; 2026 whole-chapter cutoff M.
C003	Advice about liquidation of a debt to a borrower under a credit agreement, or hirer under consumer-hire agreement, is specified in 39E(1)/(2); fact-specific advice must be distinguished from information.	S003 art.39E(1)–(2); S008 PERG17.2	H/M.
C004	Obtaining payment of certain covered obligations for a creditor, rather than counselling the debtor, invokes 39F, subject to express limitations/exclusions.	S003 art.39F(1)–(3), 39H, 39L	H/M; particular debt/actor required.
C005	Performing duties or exercising/enforcing lender/owner rights for that lender/owner invokes 39G, not merely managing the debtor's personal budget.	S003 art.39G(1)–(3)	H/M.
C006	Introductions, offers or preparatory work directed to entry into qualifying credit/hire agreements may be 36A credit broking; existing-debt referrals alone are not automatically 36A.	S003 arts.36A(1)–(4), 36B–36F	H/M; fee/exclusion distinctions preserved.
C007	Performing an act defined as providing credit-information services is a separate potential regulated activity under 89A; “credit repair” marketing alone is not a sufficient legal classification.	S003 arts.39L/72H references, 89A	M; full fact-specific 89A exclusions not closed.
C008	An agreement to carry out a specified regulated activity can itself fall within RAO 64 where its conditions apply.	S003 art.64 and adjacent exclusions	M; requires exact promised activity.
C009	Credit-related activities entered the FCA regime through the 2013 amendment order, with the principal commencement 1 Apr 2014, not the order's 2013 publication date.	S006 arts.1(2)–(6), 3–6; S007 PERG2.3.2	H.
C010	Qualifying not-for-profit bodies doing non-occasional debt adjusting, counselling or credit-information service are treated as carrying on business under business-order 3E; the occasional-only proviso limits that deeming rule.	S006 art.13, inserted 3E(1)–(4); S007 PERG2.3.2(3B)	H, constitution and frequency must be tested.
C011	Credit agreement's borrower definition concerns an individual or relevant recipient of credit; a qualifying small partnership/unincorporated body may count, an ordinary incorporated company's own debt ordinarily does not.	S003 arts.60B(3), 60L(1); S005 60B(3)	H/M; inspect organisational form and agreement.
C012	RAO 39D/39E say credit agreement, while 60B(3) differentiates regulated credit agreement; these terms cannot be interchanged.	S003 39D/E; S005 60B(3)	H text; overlap exceptions still apply.
C013	Under 60C(3) a credit agreement exceeding £25,000 wholly/predominantly for business is exempt for that chapter; 60C(5)–(6) sets declaration/rebuttal treatment.	S005 60C(1),(3),(5)–(7)	H; not a debt-advice carve-out by itself.
C014	A guarantor or third-party funder is not automatically the borrower for 39E merely by paying; a signed joint borrower can be the recipient.	S003 39E(1), 60L borrower definitions; S005 60B(3)	M—statutory-role inference; guarantee/agency specifics unresolved.
C015	Certain mortgage/home-finance overlaps are dealt with through RAO 39J and other activity classifications; security on land is not a universal 39D/39E exclusion.	S003 39J(1)–(3), 39L; S005 60C(2)	M; mortgage product and date required.
C016	39H provides role-specific lender, owner, supplier and other exclusions with limits, including the 39H(1A) qualification; a generic creditor or debt-buyer label is insufficient.	S003 39H(1)–(3), 39F/G; S005 60B(2)	H/M.
C017	“Charitable,” “free consultation” and “no debtor fee” do not themselves disapply 39D/39E: business and precise exemption tests remain necessary.	S006 art.13 / 3E; S007 PERG2.3.2–2.3.3	H, no blanket exemption.
C018	NI district council qualifies as RAO's “local authority” under art.3 and 72G excludes described local-authority acts from 39D–39G; other public bodies must establish their own basis.	S004 art.3 definition; S003 72G(1)–(3), 39L	H/M, actor identity essential.
C019	RAO 39K concerns specified barrister/solicitor acts in advocacy/litigation capacities including NI solicitor branch; general non-litigious service is not automatically excluded.	S003 39K(1)–(3)	H/M, service-specific.
C020	FSMA s.327 professional exemption requires compliance with designated-body rules, incidental/complementary professional service and financial benefit conditions, subject to 328/329 restrictions.	S001 ss.326–329, 332 as enacted; S012 PROF2.1.3–2.1.14; S013 Annex1	H FCA guidance; individual body-rule check held.
C021	RAO 72H(1)–(3) excludes stated acts as insolvency practitioner; reasonable contemplation of appointment has narrower specified 39D/39E/89A scope.	S003 72H(1)–(3), 39L; S015 CONC10.2.10G	H/M, actual appointment/capacity required.
C022	An appointed representative operates through a principal's responsibility and valid contract for eligible specified activities, not independent comprehensive authorisation.	S001 s.39; S011 SUP12	H/M, validate principal, activity eligibility and scope.
C023	The legal person carrying on in-scope debt adjusting/counselling needs its own appropriate FCA permission unless lawfully excluded/exempt/represented; permission restrictions and DMP scope matter.	S001 ss.19, 40; S003 39D/E; S014 FEES3 Annex1 CC2	H framework, actual firm permission not tested.
C024	For covered CONC10 firms, prudential requirement is the higher of £5,000 or 0.25% first £5m + 0.15% next £95m + 0.05% above, with higher-other-regime provision.	S015 10.1.1–1.2, 10.2.2–2.10	H, not compensation or segregated client money.
C025	At the 2 July 2026 pricing schedule, FEES3 CC2 restricted category 3 = £1,130 and broader category 6 £11,260 per relevant application classification.	S014 FEES3 Annex1 Part2 CC2; Annex1A	H on listed categories; combinations/actual applicant require more facts.

Actors, payment, territorial and verification claims

Claim	Exact assertion; predicates, exception and consequence	Direct source/pinpoint	Confidence / limit
C026	A payment operation is within the 2017 PSRs when a specified payment service is carried on as an independent business/regular occupation and not excluded; ordinary ancillary DMP remittance is generally not classified that way in FCA PERG Q9.	S016 regs.2, 4–5, Sch.1; S017 PERG15.2 Q9	H FCA position; contracts/cash flow determinative.
C027	Independently provided money remittance may require FCA payment-institution authorisation, small-institution registration or another valid category; FSMA permission does not automatically answer that PSR test.	S016 regs.6–14, Sch.1; S017 PERG15.2 Q11–Q11B; S018	M, all exception/threshold branches not comprehensively updated.
C028	FSMA's “carried on in the UK” link includes NI; provider/consumer/medium/location fact patterns determine reach, and non-UK location is no categorical 39D/39E exemption.	S001 s.19; S002 PERG2; S010 PERG2.4; S003 art.72	M on hypothetical overseas conduct; foreign law deferred.
C029	Violation of FSMA ss.19/20/23 has statutory regulatory/criminal consequences only on proven elements and exceptions; it does not automatically extinguish creditor obligations.	S001 ss.19–29, especially s.28(9); S002 PERG2.2	H for nonautomatic effect; full remedies deferred.
C030	FCA provides public firm checker and register; valid confirmation requires matching legal person, active status, activity permission/restriction, and AR/principal where relevant.	S033 FCA checker instructions; S034 FS Register instructions; S011 SUP12	H, no particular listing checked.
C040	NI IP bond amendment increased general penalty sum to £750,000, subject to S.R.2025/177 reg.6 saving for certain pre-2027 bond/case combinations, to address specified dishonest-loss claims.	S029 Sch.2 para.3 historic £250k; S030 regs.5–6	H, not a settlement-refund promise.
C041	CONC10 applies to an NFP debt advice body if it held £1m+ client money within last 12 months or projects that level within next 12; qualifying professional-firm exception has specific 50%-income and incidental requirements.	S015 10.1.1(2), 10.1.2(1)–(3)	H, client-money meaning not fully audited.
C043	Debt-specific personalised advice must be tested against 39E; unpersonalised information may not meet its advice element. Delivery through an algorithm does not itself settle the test.	S003 39E; S008 PERG17.2; S009 PERG17.3–17.6	M; product interactions needed.
C044	Register listing, FCA authorisation or an insolvency title does not independently establish lawful contract terms, creditor assent, debt release or successful outcome.	S033–S034 register scope; S003 regulated activities; S036 IVA distinct statutory role	H logical limitation, no specific agreement assessed.
C046	S.I.2013/1881 art.60 had a restricted not-for-profit former group-licence permission route from 1 Apr 2014, only to licence-described activities; old licence alone is not present proof of permission.	S006 art.60(1)–(3); S034 current register	H on historic transition, individual present status untested.
C047	Being licensed as an NI IP does not automatically authorise unrelated debt-adjusting services outside the 72H capacity; FSMA exemption and NI officeholding are different tests.	S003 72H; S021 s.14 / 349A; S012 PROF2.1	H/M, dual activity details needed.
C049	Business-purpose exempt credit lending under 60C does not alone remove debtor-side 39D/E where the debt remains due under a “credit agreement”; other specific exclusions may still apply.	S005 60B(3), 60C(3); S003 39D/E/H/J	H on terminology; definitive case outcome held.
C050	Debt categories like tax, rent, support, rates, fines and ordinary company trade invoices do not become 39D/E credit-agreement debt solely by label, and other legal gateways may remain.	S003 39D/E; S005 60B(3); S009 PERG17	M, other product/sector law deferred.

NI practitioner and statutory-mechanism claims

Claim	Exact assertion; predicates, exceptions and consequence	Direct source/pinpoint	Confidence / limit
C031	NI IVA is distinct statutory arrangement under NI 1989 Order Part VIII Ch.II, with statutory nominee/supervisor roles; not any private repayment negotiation.	S020 index only, Part VIII; S021 s.5, Sch.3–4; S036 IVA explanatory text	M; consolidated Order direct body access gap.
C032	An NI insolvency practitioner must be an individual, qualified/appropriately authorised under reformed 349/349A; full versus individual-only/company-only partial authorisation determines role scope.	S021 s.14(2)–(4), 349A(1)–(5); S029 reg.2/Sch.2 as amended	H for 2016 enactment; complete current RPB roster held.
C033	NI Department for the Economy supervises statutory recognition of professional bodies under reformed art.350, which authorise individual insolvency practitioners subject to training/fitness/security.	S021 ss.14–17; S029 reg.6–10, read with S030	H/M; current recognition must be verified.
C034	S.R.2025/170 removed Law Society NI as an NI insolvency RPB effective 5 Nov 2025; separate FSMA designated professional-body listing is not repealed by this instrument.	S026 arts.1–2; S028 departmental notice; S013 PROF2 Annex1	H within distinct statutes.
C035	NI Department's art.350N notice states Chartered Accountants Ireland NI insolvency RPB recognition ended 19 Feb 2025.	S027 effective-date paragraph, S026 explanatory history mentioning S.R.2025/19	M because S.R.2025/19 not itself body-read.
C036	NI DRO Official Receiver makes the statutory order; an individual “approved intermediary” under 208U(1) must have approval from a Department-designated competent authority.	S022 s.1, 208C–208E, 208U(1)–(4); S023 regs.3–10; S024	H for statutory roles, current individual designation not checked.
C037	NI 208U restricts charging debtor for activities connected to a DRO application as an approved intermediary, within the express statutory wording, not a general debt-advice-fee determination.	S022 208U(7)	H for that role only; consumer fee dossier deferred.
C038	NI bankruptcy involves NI statutory High Court/Official Receiver/trustee officeholder roles, not a generic commercial “bankruptcy adviser” licence.	S021 s.8; 1989 Order references; S029 reg.2	M, full Part IX consolidation and procedure excluded.
C039	NI 2026 s.93 abolished 1989 Order arts.237A–237G fast-track voluntary arrangement route effective 16 Oct 2026; s.93(6) preserves already-submitted specified cases.	S031 s.93(1)–(6); S032 art.2(1),(2)(n)	H, precise grandfathering predicate retained.
C042	The 2016 reform repealed NI 1989 Order article 348A and alternate authorised nominee/supervisor wording; a pre-repeal consolidated extract must not be treated as current.	S021 Sch.3 paras.4–15; Sch.4, plus s.27	H on repeal text; commencement annotation cross-check.
C045	An old NI government list of insolvency RPBs may be stale after 2025 revocations; professional-body designation and current individual licence must be checked separately.	S026–S028 revocation/effective dates, S035 directory	H as dated-list warning; no exhaustive live RPB list claim.
C048	A negotiated payment compromise is not the NI statutory IVA or DRO merely because parties call it an “arrangement”; NI statutory offices arise under their governing instrument.	S021 IVA amendments; S022 DRO statutory gateway; S036 IVA role description	H for mechanism distinction, no statement of private contract enforceability.

Claim-register completeness: 50 atomic claims, C001–C050 inclusive, with no intentionally omitted number. Claims C031, C035 and C038, and selected 2026-wide portions of C002–C008/C015–C016, retain explicit legal-currentness/source limitations. None uses an unsupplied England/Wales or other-country report as its premise.

Complete visible coverage inventory

Status definitions: A = answered within P01's limited gateway; P = partially answered because a particular amendment, body text or fact remains unverified; U = unresolved in P01; D = deliberately deferred; X = outside this jurisdiction/pass. “Next evidence/question” is a bounded research or hypothetical-document step, not an instruction to contact a provider or file an application.

A — Operative perimeter, debt/person scope and currency

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and exact next retrieval/question
A01 A	Does UK FSMA/RAO apply to covered NI activity? Yes, subject to regulated activity, business, nexus and exceptions.	C001; S001–S003, S010	For a given service: which conduct occurs in the UK? Obtain hypothetical activity map.
A02 A	What constitutes debtor-side negotiation? RAO 39D, distinct hire branch.	C002; S003 art.39D	Particular authority/agency contract and credit instrument.
A03 A	What constitutes debtor-specific repayment advice? RAO 39E, credit and hire branches.	C003; S003 art.39E, S008	Specific advice output and legal borrower identity.
A04 A	Is creditor-side collection the same permission? No; 39F separately defined.	C004; S003 art.39F	Creditor/collector contract and 39H predicates.
A05 A	Is administering a DMP necessarily debt administration? No; 39G lender/owner rights test.	C005; S003 art.39G	Whose rights/duties does actor exercise?
A06 A	Are introductions always credit broking? No; 36A specifies covered credit/hire introductions and exclusions.	C006; S003 arts.36A–36F	Destination product, commission and actual referral role.
A07 P	Is credit repair a separate permission? 89A potentially; precise subactivity must be established.	C007; S003 art.89A references	Open current RAO 89A/89B and read each exclusion against credit-repair example.
A08 A	Can agreeing now to perform later matter? Potentially RAO 64.	C008; S003 art.64	Exact engagement promise and whether future act is specified.
A09 A	What is “by way of business”? Statutory test plus 2001 Business Order, modified by specific activity and nonprofit provision.	C009–C010; S006 art.13, S007	Continuity, scale, commercial benefit and organisational constitution.
A10 A	Does a fee-free first meeting exempt a paid later service? No automatic exemption.	C017; S007 PERG2.3	Whole sales funnel, indirect consideration and substantive advice.
A11 A	Are charities/free providers automatically outside? No, art.3E has a non-occasional deeming rule.	C010, C017; S006, S007	Frequency; constitution; actual authorised/exempt legal capacity.
A12 A	Is an individual borrower included? Yes, for qualifying credit-agreement activity.	C011; S003 60L, S005 60B	Named borrower and underlying debt agreement.
A13 A	Do sole-trader business debts automatically escape? No; individual borrower and agreement exemptions are distinct tests.	C011–C013, C049; S003, S005	Loan amount, date, business-use declaration, 39H/J overlap.
A14 A	Which partnerships/unincorporated bodies are relevant? Statutory relevant-recipient definition, not every organisation.	C011; S003 art.60L	Number/type of partners and actual borrower.
A15 A	Are all corporate company debts covered by 39D/E? No, company-alone branch needs other authority.	C011–C012; S003, S005	Any separate individual borrowing/guarantee or other activity.
A16 P	Joint borrower, guarantor, third-party payer? Only actual statutory borrower/hirer status decides 39E; beneficiary/agent may matter for 39D.	C014; S003 39D/E, 60L	Current creditor agreement, guarantee and agency facts; reconcile each branch.
A17 A	Secured/unsecured/hire debts one category? No; hire and home-finance overlaps differ.	C002–C005, C015; S003, S005	Mortgage contract type and security instrument.
A18 A	Are exempt lending agreements necessarily excluded from advice? No; “credit” versus “regulated credit” text differs.	C012–C013, C049; S003, S005	Apply every relevant 39H/39J and specific contract exception.
A19 P	Are tax/rent/support/fines/utility bills necessarily FCA debt advice? Not merely by label.	C050; S003, S005	Test actual underlying agreement and any other sector authorisation.
A20 A	Did consumer-credit perimeter start merely at 2013 enactment? No; substantial transition on 1 Apr 2014.	C009, C046; S006	Historical firm-specific interim permission, if ever relevant.
A21 P	Is every RAO 39D–39L 2026 amendment independently accounted for? No, 2025 whole-part body and some 2026 narrower provisions read.	C002–C008; S003–S005	Retrieve accessible full amended Part II as at 26 Oct 2026, compare legislative changes after 15 Jul 2025 provision-by-provision.
A22 A	Is 2026 publication the same as commencement? No; 2026 NI Act and order have separate dated operative provisions.	C039; S031–S032	For additional 2026 sections, read each appointed commencement and saving before asserting operation.
A23 U	Are there further specialised trade/sector gateways for noncredit debt advice not captured here? Not determined.	C050; S003 scope boundary	Next narrow provider pass: classify any proposed pension, investment, mortgage, housing, tax or immigration advice against its own operative instrument.

B — Actors, exemptions, restricted professional capacity

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and next question
B01 A	Paid commercial debtor-side firm: 39D/E and appropriate FCA route, not a generic debt licence.	C001–C003, C023; S001–S003, S014	Who is the contracting legal person; which permissions?
B02 A	Not-for-profit/charity/free advice: no blanket immunity; art.3E.	C010, C017; S006–S007	Is activity occasional only; which entity and authorised/exempt status?
B03 P	Government-funded or public adviser: no general “public sector” exemption established.	C018; S003 72G, S004 art.3	What is exact public body and its enabling function?
B04 A	NI district council as local authority: 72G specified exclusions.	C018; S003, S004	Is the actor the council itself or a separate subsidiary/contractor?
B05 A	Solicitor litigation/advocacy: 39K specific branch.	C019; S003 art.39K	Is actual activity advocacy/litigation?
B06 P	Solicitor/accountant non-litigious professional services: conditional FSMA s.327 and body rules.	C020; S001, S012–S013	Read current specific designated body's approved s.332 rules for the service.
B07 A	Creditor collecting own debt: 39H, regulated creditor/lender-rights branch and exceptions.	C016; S003 39H, S005 60B(2)	Original ownership and whether any work is for another lender.
B08 P	Debt buyer/acquirer: role and rights can cross 60B(2), 39F/G.	C004–C005, C016; S003, S005	Assignment, servicing, original agreement and exemption predicates.
B09 A	Independent creditor collector: creditor-side permission distinct from borrower-side counselling.	C004–C005; S003 39F/G	Exact engagement and lender/owner principal.
B10 A	Referrer/publisher/software: activity and remuneration control, not label.	C006–C008, C043; S003, S008–S009	Actual information/advice interface and referral contracts.
B11 A	Ancillary DMP payment distributor: not automatically PSR payment business.	C026; S016–S017	Service independence and fund-flow arrangements.
B12 P	Independent payment remitter: another gateway may apply.	C027; S016–S019	Current PSR authorisation/registration amendments and specific arrangement.
B13 A	Statutory IP: 72H capacity-limited and separate 349A appointment.	C021, C032, C047; S003, S021	Which individual and case capacity?
B14 A	Appointed representative: principal-based s.39/SUP12.	C022; S001, S011	Actual AR contract, principal permission and covered activity.
B15 P	Special public agency/charity undertaking only NI DRO-approved work: separate 208U authority, not universal FCA exclusion.	C036; S022–S025	Does it also give other debt advice? Check 72H/other actual exemption separately.

C — Licence, application, competence and gateway financial safeguards

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and next question
COV-C01 A	FCA authorisation belongs to appropriate legal person, with named activity permission.	C001, C023; S001, S014	Exact firm/entity and restricted permission.
COV-C02 A	FCA full/limited and DMP distinctions materially affect applicant classification.	C023, C025; S014 Annex1	Apply regulatory activity group and permitted restrictions to an actual business model.
COV-C03 A	AR is exemption through authorised principal/contract for eligible activities, not free-standing licence.	C022; S001 s.39, S011	Which regulated act in principal's permission and AR contract?
COV-C04 P	Exempt professional firm has designated professional body/approved rules/incidental capacity predicates.	C020; S012–S013	Read actual current NI solicitor/accountancy body permitted-activity schedule.
COV-C05 A	NI insolvency-practitioner authorisation is individual, potentially partial by company/individual scope.	C032–C033; S021 s.14	Individual licence and authorising RPB currentness.
COV-C06 A	NI DRO competent authority designation differs from individual intermediary approval.	C036; S022 208U, S023 regs.3–10	Current competent authority and individual approval status, hypothetically.
COV-C07 P	Fitness, experience, training and qualifications for NI officeholders/advisers: meaningful regulations exist, but post-2016 consolidation must be applied.	C032–C036; S021, S023, S029	Reconcile revised Article349A with amended 2006 fitness regulations; reconcile obsolete 2011 CCA licence language.
COV-C08 P	NI DRO intermediary public-liability/indemnity insurance appears in 2011 regs.8–9.	C036; S023 regs.8–9	Read 2026 revised text and ensure exact policy coverage/amount; no universal numeric PII figure adopted.
COV-C09 A	Debt-management CONC10 financial resources and £5k floor/proportional formula are distinct from compensation/client funds.	C024; S015 10.1–10.2	For a hypothetical firm, calculate relevant debts and other higher requirement.
COV-C10 A	£1m client-money threshold for certain not-for-profit bodies affects CONC10 application.	C041; S015 10.1.1	Twelve-month actual/projection and statutory “client money” treatment.
COV-C11 A	2026 FCA applicant categories 3/6 have specified prices, not customer fees.	C025; S014 Annex1/1A	Multi-activity grouping, permission limit, not-for-profit fee exception.
COV-C12 A	NI IP bond now has £750k new standard subject to express pre-2027 saving.	C040; S029–S030	Bond issue/appointment dates and whether relevant loss within cover.
COV-C13 P	Further PII, minimum liquidity, bonding or security for other actor categories cannot be assumed.	C024, C027, C036, C040; S015–S016, S023, S030	Identify exact regulated activity and source of each proposed financial safeguard; retrieve its operative schedule.
COV-C14 A	Historic 2014 consumer-credit permission route exists but is not proof of present firm authorisation.	C009, C046; S006 art.60, S034	Modern FCA register legal entity/permission, hypothetically.
COV-C15 P	FCA accountable management, fitness, competence and threshold conditions apply according to permission and firm type.	C023–C024; S001, S002, S015	Read current COND/SYSC/SMCR-specific provisions for a defined firm; no invented single named responsible-person requirement.
COV-C16 P	Payment institution may have separate initial-capital/safeguard requirements, conditional on PSR activity.	C026–C027; S016–S019	Confirm exact 2026 amended PSR Sch.3 capital and applicable provider classification; no sum transferred to an ordinary DMP firm.

D — UK/NI and international nexus

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and next question
D01 A	NI lies inside UK FSMA geographic frame.	C001, C028; S001 s.19, S010	Where do particular regulated acts occur?
D02 A	Rest-of-UK provider into NI: UK FCA classification remains possible; NI statutory role separately governed.	C028, C031–C038; S010, S021–S023	Is service financial, insolvency officeholding or both?
D03 P	Foreign provider into NI via online/telephone: no automatic nonresident exemption.	C028; S003 art.72, S010 PERG2.4	Actual acts, agents, UK establishment and relevant RAO territorial exclusions.
D04 P	NI provider helping debtor abroad: NI place of carrying on business can matter; foreign regulatory permissions not resolved.	C028; S001, S010	Map acts in UK; A098 foreign state requirements separately.
D05 A	Website/telephone medium itself does not decide regulated activity.	C028, C043; S008–S010	Degree of personalised advice and who supplies it.
D06 P	Offshore affiliate, call-centre agent, introducer: actor-by-actor UK link necessary.	C006, C022, C028; S003, S010–S011	Agency/contracts, payments, attribution, actual location.
D07 P	Any specific treaty/overseas-person exemption for an identified nonstandard activity? Only if exact law allows.	C028; S003 art.72	Read exemption for the specific activity; 39D/E cannot borrow unrelated art.72 limb.
D08 D	Foreign recognition, creditor law, judgment enforcement and assets/migration.	C028 boundary; S010	A098: What foreign law governs the identified debtor/creditor/asset and recognition event?

E — Read-only official checking

Row / status	Verification question	Claims; official sources	Missing evidence and next check
E01 A	Is legal identity more reliable than brand name? Yes for register matching.	C030; S033–S034	Precise legal entity, trading name and signing party.
E02 A	Is an FCA listing enough? No; must inspect exact permission, status and restriction.	C023, C030, C044; S033–S034	Activity-to-permission match at relevant engagement date.
E03 A	What about AR? Match AR and principal, permitted contracted activity.	C022, C030; S011, S034	Principal permission and representation contract.
E04 P	Exempt professional firm: body listing alone insufficient.	C020; S012–S013	Firm's designated-body exempt status and current rule permitted acts.
E05 A	Separate payments register class may be necessary when independently remitting.	C026–C027; S016–S018, S034	Determine payment service first, then correct FCA category.
E06 P	NI insolvency practitioner directory: useful but not complete proof.	C032–C035; S026–S028, S035	Authorising RPB, individual licence, limited capacity, actual appointment.
E07 P	NI DRO body list: organisation status does not certify each adviser.	C036; S023–S025	Linked authority roster attachment and individual approval.
E08 A	Have actual entities/people/cases been checked? No; all procedures were hypothetical.	C030, C044; S033–S035	No additional real-case lookup within authorisation.
E09 A	Does authorisation prove settlement/debt release? No.	C044; S033–S034, S036	Later contract/creditor assent and remedy dossier; outside P01.

F — Local statutory solution and professional boundary

Row / status	NI gateway issue and limited finding	Claims; primary sources	Missing evidence and exact next question
F01 A	Private voluntary negotiation is not itself statutory NI IVA/DRO.	C048; S021–S022, S036	Does provider claim a specific statutory office or only consensual negotiating authority?
F02 P	NI IVA nominee/supervisor and Part VIII authority identified.	C031–C032, C042; S020–S021, S036	Obtain current amended 1989 Order 227–236 body and current NI IVA rules before procedural claims.
F03 A	NI insolvency practitioner is individual with appropriate/partial authorisation.	C032–C033; S021 s.14, S029–S030	Exact individual scope and current RPB confirmation.
F04 A	2016 repeal of alternative authorisation under 348A.	C042; S021 Sch.3/4	Verify commencement annotations if evaluating a historic appointment.
F05 P	NI DRO Official Receiver and approved intermediary/competent authority roles established.	C036–C037; S022–S025	Current approved-intermediary roster and 2011 licence-language reconciliation.
F06 P	NI bankruptcy High Court/Official Receiver/trustee boundary established, not full procedure.	C038; S021, S029	Read current 1989 Order Part IX/NI rules only in later bankruptcy pass.
F07 A	Law Society NI insolvency RPB recognition revoked 5 Nov 2025.	C034; S026, S028	Distinguish retained FSMA designated-professional function, then verify individual alternative RPB.
F08 P	Chartered Accountants Ireland NI insolvency RPB recognition revoked 19 Feb 2025.	C035; S027, plus S026 history	Retrieve and body-read S.R.2025 No.19 for direct independent enactment confirmation.
F09 P	Exhaustive current NI recognised professional bodies not established solely by old agency lists.	C033–C035, C045; S020–S021, S026–S028	Read S.R.1991 No.301 consolidated Schedule and every applicable 2022/2025 amendment.
F10 A	2026 fast-track voluntary arrangements repealed for new cases 16 Oct 2026, existing-submission saving.	C039; S031 s.93, S032 art.2(2)(n)	For historic cases only: was 237B(1) submission made before operative date? No actual case checked.
F11 A	NI IP general bond changed in 2025 with express transitional saving.	C040; S029–S030	Determine bond/appointment dates; no case, claim or insurance lookup.
F12 D	IVA/DRO/bankruptcy eligibility, procedure, distribution, discharge, tax and cost are not answered.	C031/C036/C038 boundary only; S020–S024	Later solution-specific dossier: what are current NI qualifying conditions, acts, forms and legal effects?

G — Hypothetical tests and quantitative safeguards

Row / status	Coverage	Claims; sources	Remaining evidence/next question
G01 A	Paid card settlement scenario G1	C002–C003; S003	Contract, borrower and permission in any actual matter.
G02 A	Nonprofit free-adviser scenario G2	C010, C017; S006–S007	Constitution, regularity and exempt/authorised capacity.
G03 A	NI solicitor commercial settlement scenario G3	C019–C020; S003, S012–S013	Current professional-body s.332 rules and incidental-service facts.
G04 A	Insolvency practitioner selling separate DMP G4	C021, C047; S003, S021	Appointment capacity versus commercial mandate.
G05 A	NI DRO competent authority/employee G5	C036; S022–S025	Individual approval and authority scope.
G06 P	Overseas app/remote NI service G6	C028, C043; S008–S010	Full territorial and functional interaction evidence.
G07 A	Acquiring/collecting creditor G7	C004–C005, C016; S003, S005	Assignment and servicer status.
G08 A	Payment-only distributor G8	C026–C027; S016–S017	Whether independent PSR payment service exists.
G09 A	FCA fee example (£1,130/£11,260, 2026)	C025; S014	Precise applicant category, no consumer fee implied.
G10 A	CONC resources examples (£5k/£20k), formula verified	C024, C041; S015	Actual relevant-debt calculation and higher parallel requirement.
G11 A	NI practitioner bond (£750k with transition)	C040; S029–S030	Bond and appointment dates; covered loss, not assumed award.
G12 A	Unauthorised activity consequence kept conditional	C029; S001–S002	Any actual allegation would require each criminal/regulatory element and defence; remedies separate.

A–G self-check: 23 A rows + 15 B rows + 16 C rows + 8 D rows + 9 E rows + 12 F rows + 12 G rows = 95 visible coverage rows. Of those, 69 A, 23 P, 1 U, 2 D. These counts reflect research dispositions, not a percentage of Northern Ireland law completed.

H — Full independently enumerated deferred-work inventory

All rows below are deliberately unanswered by P01. A reference to a gateway above supplies context only; it is not substantive authority for the deferred rule. No rule, amount, deadline, remedy or consumer entitlement is being adopted in these rows.

H1. Consumer fees, contract formation, disclosures and conduct

Row / status	Deferred rule family	Exact next research question
H001 D	Consumer-paid charges	What fees may an NI debt-management/settlement provider charge a debtor, by precisely classified activity?
H002 D	Indirect provider remuneration	How are creditor commissions, lead payments, affiliated benefits and other indirect compensation treated for disclosure, conflicts and authorisation?
H003 D	Fee earning	At what legally defined event, if any, is a provider entitled to earn a fee?
H004 D	Advance-payment restrictions	Which operative FCA/other rules limit taking money before negotiations, creditor agreement or performance?
H005 D	Fee caps and calculation	Are any statutory, regulatory or professional caps applicable, to which services, with what calculation base?
H006 D	Cancellation and withdrawal	What statutory or contractual cancellation rights, cooling-off periods and notices govern each transaction channel and provider class?
H007 D	Refunds and unearned fees	What must be returned upon cancellation, nonperformance, termination, provider failure or ineffective settlement?
H008 D	Advertising and solicitation	Which current financial-promotion, advertising, cold-calling and lead-generation restrictions apply in NI to each service?
H009 D	Written contracts	Which service contracts must be in writing, and what form, signatures or electronic-record rules apply?
H010 D	Mandatory contractual terms	Which provider promises, duration, service limitations, variation and termination clauses are mandatory, prohibited or unfair?
H011 D	Pre-contract disclosures	What must the provider disclose about fees, risks, alternatives, creditor participation, client funds and status before commitment?
H012 D	Suitability and advice standards	What assessment, suitability, vulnerability and best-interests obligations apply under relevant FCA/professional rules?
H013 D	Debt-relief outcome claims	What evidence is required for claims about savings, settlement rate, time to resolution, credit effects or guarantee?
H014 D	Ongoing service and exit	What periodic statements, reviews, records, variation notices and closure steps are required during and after engagement?

H2. Funds, redress, complaints, privacy and provider failure

Row / status	Deferred rule family	Exact next research question
H015 D	Client money receipt	When is money held by a debt adviser legally “client money” under the applicable FCA regime?
H016 D	Client money segregation	What account segregation, reconciliation, identification and audit obligations apply to a specific DMP business model?
H017 D	Stand-alone payment regulation	What is the fully updated October 2026 payment-services authorisation/registration/agent and safeguard regime, including every exemption and threshold?
H018 D	Trust and insolvency ring-fencing	If a provider fails, what proprietary or trust interest, if any, exists in money held for customers?
H019 D	Payment authority and distribution	What authority is required to initiate, distribute, withhold, reverse or refund customer payments, and what records must be retained?
H020 D	Private civil remedies	What specific cause of action, standing, limitation period, damages or restitution may follow an actual provider breach?
H021 D	Regulatory breaches and enforcement	What FCA investigative powers, notices, sanctions, procedural protections and individual accountability mechanisms apply to particular contraventions?
H022 D	Consumer complaints and ombudsman	What complaints processes and Financial Ombudsman Service jurisdiction apply to each covered legal person and service?
H023 D	NI insolvency practitioner complaints	What is the current complaint allocation among NI RPB, Department, officeholder and court, including former-RPB cases?
H024 D	Compensation schemes	When, if at all, does the Financial Services Compensation Scheme or another scheme cover a failure or a dishonest loss?
H025 D	Personal data and privacy	What UK GDPR/data-protection lawful basis, retention, data-sharing and security obligations apply to debt intake and creditor negotiation records?
H026 D	Marketing/contact permissions	What consent, privacy, telephone, email, text and direct-marketing rules apply to NI debt leads, introductions and remarketing?

H3. Debt products, collecting, disputes, time limits and credit records

Row / status	Deferred rule family	Exact next research question
H027 D	Credit card, overdraft and personal-loan products	What borrower rights, creditor duties and product-specific rules govern each source of debt in NI?
H028 D	Payday, BNPL and deferred-payment credit	Which 2026 commencement, temporary permission, product and grandfathering provisions apply to each agreement?
H029 D	Debt-collection conduct	What rules govern demands, communications, hardship treatment, harassment, third-party contact and collection practices?
H030 D	Validation and proof of debt	What evidence must an NI creditor/collector produce, when, and through what procedure?
H031 D	Balance and liability disputes	How does a debtor challenge balance, interest, ownership, accounting, fraud or contractual enforceability?
H032 D	Assignment and debt purchases	What notice, legal/equitable assignment, standing and debtor-defence rules govern transferred claims?
H033 D	Limitation periods	What NI limitation law and accrual date governs each credit, specialty, mortgage, tax or judgment claim?
H034 D	Acknowledgment, payment and revival	Which signed acknowledgment, partial payment, admission or other event affects a limitation defence in NI?
H035 D	Credit reference reporting	What source-specific reporting, accuracy, correction, suppression and retention rules apply?
H036 D	Credit score and future borrowing	What documented, qualified credit effects may follow each action, without promising score movement or recovery?
H037 D	Out-of-court creditor rights	What set-off, lien, acceleration, demand and account-closure rights arise under each creditor agreement and NI law?

H4. NI courts, enforcement, protected income and priority debt

Row / status	Deferred rule family	Exact next research question
H038 D	Court jurisdiction and claims	Which NI court or statutory forum hears the identified debt claim, and under which jurisdictional rules?
H039 D	Service of process	What are the applicable NI service methods, substituted service, cross-border service and proof requirements?
H040 D	Default and response	What actual NI procedural steps and legally operative deadlines arise after a properly served claim?
H041 D	Judgment formation	What proof and hearings are required for default, summary or contested judgment?
H042 D	Set-aside and appeal	On what grounds and under what procedure can a debtor challenge or reopen a judgment or order?
H043 D	Enforcement mechanisms	What NI enforcement office, attachment, seizure, instalment, registration and creditor-priority powers exist?
H044 D	Income/property protection	What NI exemptions or protections apply to wages, household goods, benefits, pensions and property?
H045 D	Bank accounts and third-party money	What attachment, set-off or other enforcement mechanisms may reach deposits or funds held for another person?
H046 D	Secured and mortgage debt	How do NI land charges, mortgage regulation, secured arrears and redemption interact?
H047 D	Mortgage enforcement/repossession	What NI procedure governs possession, sale, deficiency and borrower protections?
H048 D	Vehicles and hire purchase	What recovery, repossession, hire termination and secured vehicle deficiency rules govern NI agreements?
H049 D	Rent and housing	What tenancy-arrears, eviction, social-housing and housing-support rules apply in NI?
H050 D	Medical and care bills	What NI health, private treatment, care contribution and related collection rules govern the obligation?
H051 D	Utilities and telecommunications	What NI electricity, gas, water, telecom, disconnection, metering and arrears protections apply?
H052 D	Family maintenance and support	What NI child-maintenance, family-support and related enforcement priorities apply?
H053 D	Fines and criminal financial orders	Which NI criminal-court or statutory collection procedures govern fines, compensation and penalties?
H054 D	Tax, rates and other government debt	What HMRC, NI rates, overpayment recovery and government-creditor powers apply to each liability?
H055 D	Priority and nonpriority sorting	What legally supported criteria determine which NI debts have more urgent consequences or priority?
H056 D	Public assistance and free support	Which current NI public benefits, emergency assistance, housing support, debt-advice services and eligibility requirements exist?

H5. Full NI insolvency solutions, costs, cross-border work and remaining scope

Row / status	Deferred rule family	Exact next research question
H057 D	NI IVA complete procedure	What are the current NI IVA proposal, nominee, filing, creditor-decision, modification, supervision and termination rules?
H058 D	NI DRO complete procedure	What are current NI DRO eligibility, excluded debts, assets, income, applications, reviews, moratorium and discharge rules?
H059 D	NI bankruptcy complete procedure	What are the current NI petition, adjudication, trustee, estate administration, restrictions and discharge rules?
H060 D	Other NI statutory debt mechanisms	Which administration orders, compositions, debt remedies or sector-specific arrangements exist independently of IVA/DRO/bankruptcy?
H061 D	Statutory filing forms and costs	Which exact NI court/agency forms, filing charges, professional expenses and cost allocations apply at their effective dates?
H062 D	Distribution, discharge, surviving debt and tax	Which liabilities remain, how are proceeds distributed, when does discharge occur and what tax consequences follow?
H063 D	A098 foreign exchange and currency	Which currency governs each obligation, exchange conversion, payment, settlement and court calculation?
H064 D	A098 foreign contracts and governing law	Which contractual choice-of-law and mandatory protection rules determine rights under an international debt contract?
H065 D	A098 cross-border insolvency	When and how may an NI insolvency procedure be recognised abroad, or a foreign process be recognised in NI?
H066 D	A098 foreign judgments	Under what statutory/treaty/common-law route can a foreign judgment be recognised or enforced in NI, and vice versa?
H067 D	A098 relocation and offshore assets	How do change of residence, overseas income, assets, creditors and foreign collection affect rights and jurisdiction?
H068 D	Local, sector and professional overlaps	What additional NI consumer, solicitor, accountant, financial-promotion, property, mortgage, tax or contractual duties apply to a precisely identified non-gateway issue?
H069 X	All other countries and UK local regimes	Those are not adopted here. What separate jurisdiction-specific authorisation and solution rules apply if another jurisdiction is independently assigned?

H inventory count: 69 rows: 68 deferred and 1 expressly outside this jurisdiction's scope. No H row is considered answered by a citation from the gateway research.

Currentness, uncertainty and integrity holds

The most consequential remaining gaps are explicit:

U01 — RAO consolidation through 26 October 2026. The whole readable Part II was a 15 July 2025 version, supplemented by 2026 article-specific texts and FCA guidance. The attempted July 2026 whole-Part II and article 39D reads failed; therefore, not every post-July-2025 amendment to 39D–39L can be certified.
U02 — Current full NI Insolvency Order. Current complete body and selected article fetches failed or returned unsupported XHTML. This does not mean missing law. The 2010, 2016, 2025 and 2026 primary amendments were read, with operative dates and savings separated.
U03 — NI DRO intermediary rules after the FCA transfer. The 2011 regulations' historic consumer-credit-licence language needs an express contemporary statutory/interpretive reconciliation. It cannot simply be treated as a valid present-day OFT licence requirement.
U04 — Exhaustive present NI insolvency RPB list. The 2025 Law Society statutory revocation and the Department's Chartered Accountants Ireland notice are established. The remaining organisations and every licence class require a fully amended S.R.1991/301 schedule; the linked modern lists are not exhaustively body-read.
U05 — Current designated-professional-body rules. An FCA Annex identifying a designated body does not establish that a particular solicitor/accountant firm meets every FSMA s.327 condition, nor that a debt-settlement service is incidental and allowed.
U06 — Particular payment services. FCA PERG 15 materially narrows assumptions about ancillary DMP payments. A stand-alone money-transfer model still requires analysis of the fully updated payment regulations and its business facts.
U07 — Individual case capacity and territorial fact pattern. No provider, borrower, practitioner, licence, appointment, contract, judgment, payment account or cross-border transaction was examined. No conclusion depends on invented facts.
U08 — Other restricted sectors. Mortgage-specific, solicitor-conduct, tax-advice, housing, collection and insolvency-procedure regimes remain deliberately bounded off.

Two additional statutory nuances are worth retaining when this work is continued:

RAO article 36C excludes certain 36A(1)(d)–(f) no-fee credit-broking activities, with “fee” including other financial consideration; its wording does not necessarily exclude 36A(1)(a)–(c) introductions. This qualification belongs with C006, supported by S003 arts.36A/36C. legislation.gov.uk
RAO article 39I has a specific exclusion for a relevant energy supplier acting in that capacity in relation to an associated Green Deal plan, and 39J deals only with its specified mortgage/home-purchase overlap to the extent the activity is otherwise regulated. Neither is a blanket exclusion for utility or secured debt. This further confines C015/C050, supported by S003 arts.39I–39J. legislation.gov.uk

Final self-check and acceptance disposition

Required deliverable	Visible result
Primary browsing/body reads	Yes, UK Acts/SIs, FCA Handbook, NI Acts/SRs and Department pages; precise failures and limited attachments identified
Source register	36 numbered S001–S036, direct literal URLs, provisions, applicable dates, jurisdiction, read status and PDF indices where relevant
Atomic claim register	50 numbered C001–C050, with scoped predicates, exclusions, consequence, primary-source pinpoint and confidence
A–G coverage	95 rows
H deferred inventory	69 rows
Total visible coverage rows	164
Four or more scenarios	Eight bounded hypotheticals, each containing facts, tests, responsible gateway, missing facts, adverse branch and verification documents
At least two sourced quantitative examples	FCA 2026 application-category charges, two CONC10 computations, NI 2025 IP bond and 2027 saving
Actual person/provider/consumer/firm verification	None
Publication, external contact, filing, purchase, website or file alteration	None
Reliance on failed/unreviewed other-country research	None
Independent second-person review or all-law certification	None claimed

Arithmetic correction to the earlier A–G status line: Recounting each displayed row gives 64 answered, 28 partial, 1 unresolved and 2 deferred, totaling 95. Adding H yields 64 answered, 28 partial, 1 unresolved, 70 deferred and 1 outside scope, totaling 164. This corrects the interim 69/23 status split without changing any underlying row or finding.

Disposition: C_NI PASS-01 submitted as a first narrow independent provider-classification and authorisation investigation, with the specified holds. It is not an independent review, a complete Northern Ireland country report, approval of a particular provider or a determination of any consumer remedy. Parent, A097 and A098 acceptance remain held. The broad root-country assignment remains unlaunched.

END C_NI PASS-01.

Every captured table

Captured cells with original header handling and explicitly labeled bounded correction overlays. Downloaded JSON retains original cells. Tables may contain source limitations, historical examples and identified corrections; the complete reading supplies context.

How to read the research →

4 pending corrections

This dated research component contains identified issues. Read the correction panel before relying on its affected passages or tables. Other findings retain their own evidence limits.

Captured table 01

Original headerless table; first data row retained · 12 data rows

Actual service or feature	Operative test	Preliminary classification, including adverse branch	Claims
Negotiating lower balances or repayment terms for a borrower	RAO 39D(1): negotiating with lender on borrower’s behalf concerning discharge of a credit-agreement debt, taking over discharge obligations for payments, or analogous liquidation activity	Potential debt adjusting. An agreed lump-sum settlement is not necessarily outside the activity simply because no monthly debt-management plan exists. Check precise exclusions.	C002, C016
Similar negotiation for a hirer	RAO 39D(2); underlying consumer-hire agreement	Also potentially debt adjusting, although the product is hire rather than a loan.	C002
Advising a borrower to pay, compromise or otherwise liquidate a particular credit debt	RAO 39E(1)	Potential debt counselling even without negotiations, custody of funds, or a signed plan. A free first meeting does not, by itself, settle the “by way of business” inquiry.	C003, C009
Advising a hirer about a specific consumer-hire debt	RAO 39E(2)	Potential debt counselling, separately tested.	C003
General budgeting, factual explanations or an impersonal educational article	Advice about liquidation of a specified borrower’s covered debt? See FCA PERG 17	May be outside 39E if genuinely general information. Personalized selection of a debt strategy can change the answer. “Educational software” is not itself an exemption.	C043
Collecting debts for creditors	RAO 39F and exclusions	Debt collecting is a distinct creditor-side activity; not synonymous with borrower-side 39D. Applicable debt type, creditor status, and exclusions matter.	C004, C016
Exercising or enforcing a lender’s/owner’s rights on its behalf	RAO 39G	Potential debt administration. Merely administering a borrower’s repayment budget is not automatically 39G.	C005
Referring someone to a consolidation loan or presenting a new credit product	RAO 36A, depending on the introduction, borrower, intended agreement, and exemptions	Potential credit broking. A referral solely to obtain existing-debt advice is not automatically credit broking.	C006
Helping correct credit-report information	RAO 89A credit-information services	A separate possible regulated activity; the exact acts and exceptions must be established.	C007
Agreeing to provide one of the regulated services later	RAO 64 where applicable	An agreement to perform a covered regulated activity can itself require analysis.	C008
Holding or forwarding debtor payments	RAO debt activities plus Payment Services Regulations 2017, if applicable	Payment-service authorisation is not automatic for an ordinary ancillary debt-management-plan distribution; an independently operated money-remittance business may cross another gateway.	C026–C027

Captured table 02

Original headerless table; first data row retained · 12 data rows

Branch	Result at this gateway	Missing fact that could change it
Individual borrowing personally	Normally the clearest potential credit-agreement borrower within articles 39D/39E. Not every individual debt is a credit-agreement debt. [C011–C012]	Original contract, creditor identity, debt source and advice actually delivered
Sole trader	May be an “individual” borrower notwithstanding business purpose. A business-purpose exemption from lender regulation under article 60C is not automatically an exemption from 39D/39E, whose wording uses “credit agreement.” [C011–C013, C049]	Whether borrower is individual; loan amount, business purpose, date and nature of agreement
Small partnership/unincorporated organisation	The statutory definition of relevant recipient of credit can include a partnership of two or three persons, and specified small unincorporated bodies; it does not mean every partnership. [C011]	Constitution, partners, borrower named, whether relevant statutory definition met
Incorporated company owing its own trading debt	Company borrowing ordinarily does not satisfy the article 60B individual/relevant-recipient formulation. Do not infer an FCA 39D/39E licence is required for that corporate debt solely from this category. [C011–C012]	Is a human also borrower, guarantor or party to a separate credit agreement? Other regulated activity?
Joint borrowers	Each person legally designated borrower may trigger the borrower-facing test. [C014]	Signed agreement and allocation of contractual obligations
Guarantor or family member paying for someone else	Status as payer or guarantor does not automatically make that person the statutory borrower receiving 39E advice. Conversely, an adviser representing the actual borrower may be conducting 39D. [C014]	Guarantee, borrower identity, agency and advice recipient
Personal secured loan	Security alone does not remove the debt from analysis. Mortgage/home-finance overlaps and RAO 39J require separate classification. [C015]	Land security, first/second charge, mortgage-regulated status and loan terms
Hire purchase/consumer hire	Examine both credit and consumer-hire limbs; distinguish owner’s rights, hirer’s debt and any regulated hire exceptions. [C002–C005]	Hire agreement, owner, hirer and activity
Credit agreement exempt from the lender’s Part 14A regime	RAO 60B(3) defines “credit agreement” separately from “regulated credit agreement”; 39D/E use the former. It is therefore unsafe to equate exempt agreement with unregulated debt advice. [C012–C013]	Specific exemption, 39H/39J/other exclusions, agreement date
Rent arrears, rates, income tax, fines, utilities, support arrears or ordinary trade invoices	No automatic 39D/39E classification solely from these debt labels. Other UK/local legal gateways could still be relevant. [C012, C050]	Did any obligation actually arise under a covered credit/hire agreement, or is there another regulated transaction?
Mixed debts	Classification is activity-by-activity and debt-by-debt. One credit-card debt may make a portion of a proposed paid service regulated even where accompanying tax/rent advice is not 39E. [C003, C012]	Schedule matching each obligation to its governing instrument

Captured table 03

Original headerless table; first data row retained · 15 data rows

Actor or asserted status	Actual legal route or exclusion	What is not established	Claims
Paid private settlement negotiator	FCA Part 4A permissions for relevant RAO activities unless an actual exclusion/exemption applies	A Companies House or ordinary business registration is not permission.	C001–C003, C023
Paid DMP operator	Usually investigate debt adjusting and counselling, precise FCA permission and any DMP restriction; CONC 10 resources if within application	“Authorised” without corresponding specific activity and restrictions is not enough.	C023–C024
Charity/not-for-profit debt adviser	The Carrying on Regulated Activities by Way of Business Order 2001, art. 3E, expressly treats qualifying not-for-profit bodies undertaking specified non-occasional debt adjusting, counselling and credit-information services as operating by way of business. Constitution/public-purpose/no-distribution predicates matter.	“Free,” “charity” or “no debtor fee” is not a blanket FCA exemption. [C010, C017]	C010, C017
Infrequent nonprofit assistance	Article 3E(2) excludes activities carried on only occasionally from that deeming provision	This is not a declaration that every occasional case is free of all other statutory tests.	C010
NI district council acting itself	RAO 72G local-authority exclusion applicable to articles 39D–39G; RAO art. 3 defines local authority for NI as a district council	Neither every “government-funded” organisation nor every council affiliate is automatically within the precise statutory exclusion.	C018
Public advice department or agency that is not an NI district council	Identify the exact statutory personality, function and any specific exemption	“Public sector” does not itself equal RAO 72G.	C018
NI solicitor acting in litigation/advocacy	RAO 39K excludes relevant barristers and solicitors acting in specifically described advocacy/litigation capacities	General non-litigious commercial debt settlement is not universally excluded merely by a solicitor practising certificate.	C019
Solicitor/accountant firm providing incidental regulated services	FSMA Part XX, especially s.327, and designated-body rules under ss.326/332 may provide exempt professional firm status if all conditions hold: professional membership/control, complementary/incidental activity, approved body rules, treatment of outside reward, and any restrictions/directions.	A professional title alone is insufficient. Law Society NI's role as an FSMA designated professional body must not be confused with its former NI insolvency-practitioner recognising role.	C020, C034, C047
Creditor collecting or restructuring its own claim	Specific RAO 39H lender/owner/supplier exclusions for certain 39D–39G acts, alongside lender-rights rules under 60B and exceptions such as the 39H(1A) debt-collecting qualification	A third-party collector or independent debt purchaser cannot rely on a broad “creditor exemption” without testing the legal capacity.	C016
Debt buyer, servicing firm or collection agency	Examine rights acquired, whether acting for lender/owner, article 39F, 39G, 60B(2) and 39H conditions	Creditor-side activity does not prove borrower-side counselling permission.	C004–C005, C016
Pure information publisher or software vendor	No activity-based exemption merely because delivery is electronic. Examine functionality, influence on a particular debtor’s decision, operator and benefit.	“AI,” “self-service” or “referral website” is not an FCA-authorised class.	C006–C008, C043
Payment-only distributor	First distinguish ancillary distributions under a DMP from payment service independently carried on as a business under the 2017 Payment Services Regulations	Neither universal payment-service licensing nor universal exclusion can be inferred.	C026–C027
Statutory insolvency practitioner	RAO 72H excludes certain activities while acting as an insolvency practitioner; a narrower prospective-appointment exclusion covers 39D, 39E and 89A in reasonable contemplation of appointment.	The same practitioner's separate retail debt-negotiation venture cannot use a general lifelong exclusion.	C021, C047
Appointed representative (AR)	FSMA s.39 and FCA SUP 12 where an eligible activity is covered by a principal's agreement and corresponding permission, with principal responsibility	AR status for an unrelated permission does not cover debt adjusting. Verify scope and FCA listing.	C022

Captured table 04

Original headerless table; first data row retained · 5 data rows

Sourced gateway example	Computation or amount	Crucial limit
2026 FCA Part 4A application fee, FEES 3 Annex 1/1A	CC2 debt adjusting/counselling in the restricted category 3: £1,130; broader category 6: £11,260 (Annex 1A effective 2 July 2026)	Only if the applicant fits that category. No customer fee is stated or implied; multiple-activity and special-classification rules may alter an application. [C025]
CONC 10 prudential resources, £2 million relevant debts under management	£2,000,000 × 0.25% = £5,000; compare £5,000 floor ⇒ £5,000	Applies only to covered firms/debts; not £5,000 held for each customer. [C024]
CONC 10 prudential resources, £10 million relevant debts under management	First £5m × 0.25% = £12,500; next £5m × 0.15% = £7,500; total £20,000	If another regulated activity imposes higher prudential resources, use the higher requirement. [C024]
NI insolvency practitioner bond, general penalty sum	2025 amendment substitutes £750,000 for £250,000	Transitional saving: qualifying bond issued and practitioner appointed before 1 January 2027 can remain under prior terms. Fraud/dishonesty bond cover—not a universal debtor refund or guarantee. [C040]

Captured table 05

Original headerless table; first data row retained · 6 data rows

Hypothetical nexus	Narrow decision
NI firm advising NI borrower by telephone	Test UK regulated activity and precise RAO permission/exclusion; medium is not a safe harbour.
Firm elsewhere in the UK soliciting NI customers	UK-wide FCA perimeter may apply, but local NI statutory solution roles remain a separate legal test.
Overseas firm with no NI premises selling paid, tailored advice into NI	Do not infer “outside FCA jurisdiction.” Assess where conduct occurs, UK connection, actual FSMA territorial construction and any specific exemption. RAO article 72 overseas-person exclusions are not a blanket exclusion from debtor-side 39D/39E.
NI company advising debtors abroad	The NI establishment can supply a UK nexus; a foreign client's residence does not by itself cancel the UK test. Foreign local licensing is deferred to A098.
Offshore marketing affiliate or call centre	Identify which legal person markets, advises, refers, negotiates, receives commission or money, and who is principal/agent. Treat each activity and jurisdictional connection independently.

Captured table 06

Original headerless table; first data row retained · 9 data rows

Step	Document/fact to obtain hypothetically	Official comparison and decision
1. Establish entity	Exact legal name, legal form, any trading names, registered address and the party signing the engagement	Do not check a brand name alone against a regulator entry.
2. Classify conduct	Who gives advice, negotiates, proposes plan, receives commission, collects money, introduces credit or claims to be an officeholder	Map to RAO 39D/E/F/G, 36A, 89A, or payments/NI insolvency gateway as appropriate. [C002–C008]
3. Match debt and recipient	Agreements; named borrower/hirer; guarantor role; original purpose; secured status; debt-by-debt schedule	Confirm the legal subject matter before interpreting “permission.” [C011–C015]
4. Verify FCA category	FCA Financial Services Register and FCA Firm Checker	Inspect status, legal entity, permission wording, restrictions, effective periods and, for ARs, principal and covered capacity. Do not treat simple listing as unrestricted approval. [C030, C044]
5. Verify NI IVA/bankruptcy practitioner status	Individual's claimed RPB, licence scope and actual statutory appointment	Use the NI Department for the Economy's insolvency practitioner directory, understanding directory completeness/opt-in limitations, and the appropriate authorising body's status evidence. [C032–C035]
6. Verify NI DRO adviser capacity	Claimed approved intermediary, its competent authority, and current approval; not merely charity employment	Compare against the Department's designated competent authorities list; the authority's approval of the individual is the further question. [C036]
7. Verify cash-flow category	Whether consumer pays creditor directly, through the debt firm, through a third-party payment provider, or via standalone money remittance	Determine the actual payer/payee/service and if a separate payment-services permission/registration must be checked. [C026–C027]
8. Keep conclusion conditional	Capacity, permission, exclusions and relevant dates	A regulator listing proves neither creditor agreement to settle, contractual fairness, lawful customer fees, release of debt, nor settlement outcome. [C044]

Source links captured in this table

Captured table 07

Original headerless table; first data row retained · 7 data rows

Mechanism/capacity	NI source and decision maker	Gateway distinction and currentness
Private voluntary repayment/settlement negotiation	Ordinary debtor-creditor negotiation; FSMA/RAO only if covered activities are undertaken	No private “settlement proposal” becomes a statutory NI IVA simply by being called an arrangement. A firm may need FCA permission but not NI IVA nominee status merely to negotiate privately. [C048]
Individual voluntary arrangement (IVA)	Insolvency (Northern Ireland) Order 1989, Part VIII, Chapter II; NI High Court and qualified nominee/supervisor according to relevant procedure	An appropriately authorised individual insolvency practitioner is the operative professional route. The older alternative authorised-nominee wording and Article 348A were repealed by the Insolvency (Amendment) Act (Northern Ireland) 2016, Schedule 3/4. Do not resurrect them from an older consolidation. [C031–C032]
Debt relief order (DRO)	NI 1989 Order Part VIIA as introduced by the Debt Relief Act (Northern Ireland) 2010: Official Receiver determines order; Article 208U approved intermediary assists in applications under approval from a Department-designated competent authority	An organisation's designation does not by itself mean every staff member is individually approved. There is an express Article 208U restriction on intermediary charges connected with the application; the wider consumer fee dossier is deferred. [C036–C037]
Bankruptcy	NI 1989 Order bankruptcy provisions; NI High Court, Official Receiver and appropriately qualified statutory officeholder capacities	No ordinary private debt counsellor becomes a trustee/Official Receiver. Full court petition and trustee powers are deferred. [C038]
Fast-track voluntary arrangements	NI 2026 Act s.93, commenced by S.R. 2026 No.180, art.2(2)(n)	Repealed for new cases from 16 October 2026, but s.93(6) expressly preserves cases in which the debtor supplied the specified documents to the Official Receiver before commencement. An older government or statutory index may still display the former route. [C039]
Recognised professional body (RPB) authorising an NI insolvency practitioner	NI 1989 Order articles 349/349A/350, as substantially amended in 2016; Department for the Economy recognises/oversees bodies; authorised individual, potentially full or individual-only/companies-only partial authorisation	Check current body recognition and the specific individual's authorisation and case capacity. A generic accountant/solicitor title or RPB trade membership does not suffice. [C032–C035]

Captured table 08

Original headerless table; first data row retained · 9 data rows

Scenario and known facts	Actual test / provisional result	Missing facts and adverse branch	Decision maker, documents, next read-only check
G1. Paid card settlement. An NI company charges customers to telephone credit-card lenders and seek reduced settlements for the cardholders.	Strong potential 39D debt adjusting; any borrower-specific repayment recommendations add 39E. [C002–C003]	Legal borrower, nature of each card debt, full service and any exclusion. “One-off settlement” does not alone defeat 39D.	FCA gateway. Engagement terms, service scripts, agreements, company identity; compare FCA status, 39D/39E permissions and restrictions.
G2. Free charity debt clinic. An NI charity regularly advises individuals about their named card and hire debts without billing those individuals.	Articles 39D/E if acts occur; business-order art.3E may deem non-occasional covered charity activity by way of business. [C003, C010]	Charity constitution, legal entity, how regularly it advises, actual regulatory route. No customer fee is not exemption.	FCA or valid exemption route. Constitution, funding/benefit, case workflow, exact authorisation/exempt-capacity evidence; check FCA record or governing exemption.
G3. Solicitor-led negotiations. A practising NI solicitor proposes a non-litigious telephone debt-settlement service as a stand-alone paid offering.	RAO 39K advocacy/litigation exclusion cannot automatically be applied. Test FSMA s.327 professional-firm conditions or appropriate FCA permission. [C019–C020]	Are services genuinely litigation/advocacy or incidental to supervised professional work? Separate remuneration, advertising, body rules, entity structure.	Law Society NI designated professional-body capacity and/or FCA. Practising status, firm structure, activity descriptions, remuneration agreement; compare actual exempt-professional conditions.
G4. Insolvency practitioner also sells private DMPs. An NI-authorised individual acts as IVA supervisor in one matter but separately markets monthly repayment negotiation to unrelated people.	RAO 72H applies to acts in IP capacity, not automatically to the separate DMP business. [C021, C047]	Which entity contracts, appointments, case files and acts are in which capacity?	NI authorising RPB for statutory office; FCA for separate regulated service. Licence/appointment documents and separate DMP engagements; check both gateways distinctly.
G5. “DRO approved” staff member. A debt charity appears on an NI competent-authority list, and an employee offers to file a DRO.	Article 208U requires a specifically approved individual through a designated competent authority. [C036]	Whether employee is approved, whether approval remains effective, capacity and restrictions. Organisation listing alone insufficient.	NI designated competent authority / Official Receiver. Organisation designation and individual's approval evidence; use published authority list without making any actual-person query.
G6. Outside-UK app selling NI debt recommendations. A foreign website accepts an NI customer's debt figures, suggests settlements and takes a referral payment.	FCA PERG 17 helps distinguish factual information from debt counselling; FSMA UK territorial nexus remains fact-sensitive. [C006, C028, C043]	Provider establishment, recipient, where personalised advice occurs, affiliate roles, fee/benefit, debt source. “Foreign site” alone not exclusion.	FCA perimeter plus deferred foreign-law analysis. Product demonstration, terms, referral agreements, operator chart and data flow; match each act to permissions.
G7. Debt buyer enforces acquired loans. A company buys outstanding borrower receivables and pursues payments for itself, without taking customer debt-advice mandates.	Examine 39H, 39F/G, 60B(2) and acquired lender rights; not automatically 39D. [C004–C005, C016]	Legal assignment, ownership vs servicing, covered agreement, whether collector acts for itself/another.	FCA. Assignment and servicing contracts, product samples, collector's activities; compare permission for exercising lender rights/collecting/administration.
G8. Payment distributor. A processor receives customers’ instalments and sends them to creditors; it does not advise or negotiate.	Determine whether it independently provides regulated money remittance under the 2017 Regulations or merely performs ancillary DMP distributions under FCA PERG 15.2 Q9. [C026–C027]	Who holds funds, for whose account, source of instructions, business model, contractual status and any separate payment service.	FCA payments gateway where triggered. Flow-of-funds schematic, user contract and processing arrangement; check appropriate payment-institution/agent category rather than assuming a debt-adjusting licence.

Captured table 09

Original headerless table; first data row retained · 20 data rows

ID / status	Issuer, direct official URL and exact portion read	Version/effect; actor, debt and jurisdiction limits
S001 B	UK Parliament, Financial Services and Markets Act 2000, original enacted PDF; ss.19–23, 26–29, 39–40, 326–327 and 332. PDF P27–P32, corresponding original printed pp.8–13 for main prohibitions/remedies; P36–P37, printed pp.17–18 for representative/application route. https://www.legislation.gov.uk/ukpga/2000/8/pdfs/ukpga_20000008_en.pdf	As enacted 2000 only, not a reliable modern consolidation. UK including NI, persons conducting regulated activities. Used with current FCA guidance/amending law; original statutory wording is not asserted unchanged in all respects. legislation.gov.uk
S002 B	FCA, PERG 2—Authorisation and regulated activities, especially 2.2 prohibition/permission and 2.4, 2.8–2.11 scope/exemption context. https://handbook.fca.org.uk/handbook/perg2?timeline=true	Current FCA Handbook display accessed 26 Oct 2026; relevant interface shows changes through 16 Sept 2026. Guidance (G), UK regulated activities and NI nexus, not a statutory substitute. PERG 2 Authorisation and regulated activities
S003 B	UK Treasury, Regulated Activities Order 2001, Part II arts.4, 36A, 39D–39L, 60-series references, 64, 72, 72G, 72H, 89A references, detailed exceptions/annotations. https://www.legislation.gov.uk/uksi/2001/544/part/II/2025-07-15/data.html	Official 15 July 2025 point-in-time consolidated body. UK except express geographic limits; credit agreements/hire and regulated services. July–Oct 2026 Part II whole-part consolidation was unavailable, so amendment completeness after that date is held. legislation.gov.uk
S004 B	UK Treasury, same RAO, article 3 interpretation, including NI local authority and insolvency-practitioner cross-references. https://www.legislation.gov.uk/uksi/2001/544/article/3/2026-02-25/data.html	25 Feb 2026 point-in-time body, UK/NI definition branch; does not certify all changes after selected date. legislation.gov.uk
S005 B	UK Treasury, same RAO Part II Ch.14A, arts.60B and 60C(1)–(8), credit/regulated credit and business-purpose exemptions. https://www.legislation.gov.uk/uksi/2001/544/part/II/chapter/14A/crossheading/the-activities/2026-07-15/data.html	15 July 2026 point-in-time body, individual/relevant recipient of credit; distinguishes borrower and lender permissions from debt-counselling activities. legislation.gov.uk
S006 B	UK Treasury, S.I.2013/1881, Financial Services and Markets Act 2000 (Regulated Activities) (Amendment) (No.2) Order 2013: art.1(2)–(6), arts.3–5, art.13 inserting business-order art.3E, art.60 grandfathering. PDF P0–P3 printed pp.1–4; P31–P32 printed pp.32–33; P68 printed p.69. https://www.legislation.gov.uk/uksi/2013/1881/pdfs/uksi_20131881_en.pdf	As-made enactment, central operative date 1 April 2014 subject to preparatory/transitional commencement. Historical group-licence provisions not general 2026 permission. UK including NI. SI20130726rvsdRAONo2130725
S007 B	FCA, PERG 2.3.1–2.3.3 “The business element”; nonprofit art.3E, occasional business and case factors. https://handbook.fca.org.uk/handbook/perg2/perg2s3	FCA G, current displayed version last updated 16 Sept 2026, future version indicated for 2027 (not yet operative). UK covered actors. PERG 2.3 The business element
S008 B	FCA, PERG 17.2 basic debt-counselling elements, borrower, particular credit debt and advice. https://handbook.fca.org.uk/handbook/perg17/perg17s2	FCA G, current interface viewed; UK including NI, particular credit/hire debt advice. handbook.fca.org.uk
S009 B	FCA, PERG 17 consolidated consumer-credit debt-counselling questions and examples, general information versus borrower-specific assessment. https://handbook.fca.org.uk/handbook/perg17	FCA G, 26 Oct 2026 access; UK covered debt advice. Guidance examples cannot settle unspecified software behaviour. PERG 17 Consumer credit debt counselling
S010 B	FCA, PERG 2.4, link between regulated activities and the UK. https://handbook.fca.org.uk/handbook/perg2/perg2s4?timeline=true	FCA G, displayed current at access; UK territorial operation, overseas and NI services. No foreign-state licensing certification. handbook.fca.org.uk
S011 B	FCA, SUP 12, appointed representatives: responsibilities, contractual scope, oversight and relevant registration. https://handbook.fca.org.uk/handbook/sup12	Current FCA Handbook section as accessed; R/G depending provision. AR/principal route for activities lawfully eligible; UK including NI. SUP 12 Appointed representatives
S012 B	FCA, PROF 2.1.1–2.1.14, FSMA ss.326–329, 332 professional-firm gateway and restrictions. https://handbook.fca.org.uk/handbook/prof2/prof2s1	FCA G; display last updated 23 Oct 2025 (subrules have own dates). UK designated professional bodies and regulated incidental services. handbook.fca.org.uk
S013 B	FCA, PROF 2 Annex 1.1, designated bodies including Law Society of Northern Ireland and accountancy bodies. https://handbook.fca.org.uk/handbook/prof2/prof2s2?timeline=true	FCA G annex updated 6 July 2006; historic designation list—current applicability also conditional upon statutory/body rule changes. Not the NI insolvency RPB roster. handbook.fca.org.uk
S014 B	FCA, FEES 3 Annex 1, Part 2 activity groups CC1/CC2; Annex 1A pricing categories; FEES 3.2. https://handbook.fca.org.uk/handbook/fees3	Binding R fee provisions; Annex 1A last updated 2 July 2026: category 3 £1,130, category 6 £11,260. Application fees only, subject to category/other rules; UK including NI. handbook.fca.org.uk +1
S015 B	FCA, CONC 10.1.1–10.1.6, 10.2.1–10.2.14, prudential-resource application, £1m nonprofit test, formula, £5k minimum, professional exception. https://handbook.fca.org.uk/handbook/conc10	Binding R versus marked G. Chapter shows last update 1 July 2014; current interface accessed 26 Oct 2026. Applicable UK debt-management firms including NI; not every debt adviser. handbook.fca.org.uk +1
S016 B	UK Treasury, Payment Services Regulations 2017, regs.2, 4–5; Sch.1 Part 1 para.1(f), Part 2; Sch.3. PDF, P11–P14 printed approximately pp.12–15; P93–P96 printed pp.94–97 for capital/own funds. https://www.legislation.gov.uk/uksi/2017/752/pdfs/uksi_20170752_en.pdf	As-made 2017, later changes not comprehensively consolidated here. Payment institutions, stand-alone remittance and exclusions; UK including NI. Not an automatic classification for DMP transfers. legislation.gov.uk
S017 B	FCA, PERG 15.2 Q9, Q11–Q11B, payment activity as a business in its own right, ordinary ancillary DMP examples and dual FSMA/payment capacities. https://handbook.fca.org.uk/handbook/perg15/perg15s2	FCA G current accessed page; UK payment-service providers, including NI; fact-sensitive exception, not unconditional authorisation. PERG 15.2 General
S018 B	FCA, Apply to become an electronic money or payment institution, application/registration gateway. https://www.fca.org.uk/firms/apply-emoney-payment-institution	FCA official page current accessed 26 Oct; webpage last-updated marker 20 Aug 2026. Payment providers, not every debt firm; procedural costs/details outside narrow pass. FCA
S019 B	FCA, Safeguarding requirements for EMIs and payment institutions, scope of payment-institution safeguards. https://www.fca.org.uk/firms/emi-payment-institutions-safeguarding-requirements	FCA official page current at access; includes 2026 material, but no full client-money/safeguarding audit undertaken. UK including NI when payment gateway actually applies. FCA

Captured table 10

Original headerless table; first data row retained · 18 data rows

ID / status	Issuer, direct official URL and exact portion	Version/effect; actor, debt and jurisdiction limits
S020 F/I	UK legislation publisher, Insolvency (Northern Ireland) Order 1989, S.I.1989/2405 (N.I.19), attempted full contemporary revision and narrower arts. 3, 208U, 227–236, 348–350. https://www.legislation.gov.uk/nisi/1989/2405/2026-06-25/data.html	26 Oct 2026 full-body fetch failed (timeout); separate article pages produced unsupported XHTML. Search-index extracts of 349 and 208U were viewed but not treated as body-read. Historical and subsequently amended text separately supported by S021–S032. This is an explicit current-consolidation gap. Internal Error +2
S021 B	NI Assembly, Insolvency (Amendment) Act (Northern Ireland) 2016, ss.14–17; Schedule 2 transition paras.11–16; Schedule 3 paras.4–15; Schedule 4 repeal of arts.348A/351–354. PDF P13–P17, printed pp.10–14; P40–P44, printed pp.37–41. https://www.legislation.gov.uk/nia/2016/2/pdfs/nia_20160002_en.pdf	Enacted 29 Jan 2016; substantive provisions commenced separately, notably 2016 officeholder reform and repeal. NI only; authoritative amended statutory wording, not proof that every provision was effective at Royal Assent. legislation.gov.uk +1
S022 B	NI Assembly, Debt Relief Act (Northern Ireland) 2010, s.1 introducing 1989 Order Part VIIA; arts.208A–208E and 208U, especially intermediary and competent authority. PDF P1–P4 printed pp.1–4; P15–P17 printed pp.15–17. https://www.legislation.gov.uk/nia/2010/16/pdfs/nia_20100016_en.pdf	As enacted 2010; commenced by separate instruments, not assumed immediately effective. NI DROs only. Later threshold/qualification amendments not audited in this narrow gateway. Front Cover of Act.doc +1
S023 B	NI Department, Debt Relief Orders (Designation of Competent Authorities) Regulations (Northern Ireland) 2011, regs.2–10: designation, fit/proper body, restricted designation, individual intermediary approval, training/insurance/documents. PDF P0–P5, printed pp.1–6. https://www.legislation.gov.uk/nisr/2011/15/pdfs/nisr_20110015_en.pdf?wrap=true	As-made 2011. References to historic consumer-credit licensing require 2014/current-law reconciliation. NI DRO competent authorities and individual intermediaries. N4713_floating.doc +1
S024 B	NI Department for the Economy, Debt Relief Orders, discussion of Official Receiver, approved advisers and agency role, especially page sections “What is a debt relief order?” and “More information.” https://www.economy-ni.gov.uk/topics/debt-relief-orders	Live NI agency page accessed 26 Oct 2026; may include newer product eligibility thresholds not adopted in P01. NI public guidance, not a substitute for individual approval. Department for the Economy
S025 B	NI Department for the Economy, List of competent authorities in relation to the debt relief scheme, publication metadata and designated-organisation document link. https://www.economy-ni.gov.uk/publications/list-competent-authorities-relation-debt-relief-scheme	Published 26 May 2015, last updated 22 Apr 2024. Page body-read, linked Word attachment not body-read. Thus names/completeness of the current list are not certified. Department for the Economy
S026 B	NI Department for the Economy, S.R.2025 No.170, Insolvency Practitioners (Recognised Professional Bodies) (Revocation of Recognition) (No.2) Order (NI), arts.1–2. PDF P0–P1, printed pp.1–2; explanatory P2, printed p.3. https://www.legislation.gov.uk/nisr/2025/170/pdfs/nisr_20250170_en.pdf	Effective 5 Nov 2025; removes Law Society of NI from NI insolvency RPB schedule. Not an FSMA s.326 designation repeal. legislation.gov.uk
S027 B	NI Department for the Economy, Insolvency Service notice—revocation of recognition of the Institute of Chartered Accountants in Ireland as an RPB, paragraphs about art.350N and effective date. https://www.economy-ni.gov.uk/articles/insolvency-service-notice-revocation-recognition-institute-chartered-accountants-ireland-recognised-professional-body-economy-0	NI Department notice: 19 Feb 2025 effective; describes move of authorisations. The corresponding S.R.2025 No.19 was not separately body-read, a narrower evidentiary limit. Department for the Economy
S028 B	NI Department for the Economy, Insolvency Service notice—Law Society NI RPB recognition revocation, art.350N notice/reasons. https://www.economy-ni.gov.uk/publications/insolvency-service-notice-revocation-recognition-law-society-northern-ireland-recognised-professional-body	Dated 5 Nov 2025; confirms practitioner transition, distinct from FCA designated-professional status. NI specific. Department for the Economy
S029 B	NI Department, Insolvency Practitioners Regulations (Northern Ireland) 2006, especially regs.2, 6–10, 12 and Sch.2 paras.1–3. PDF P2–P5, printed pp.3–6; bond P11–P13, printed pp.12–14. https://www.legislation.gov.uk/nisr/2006/33/pdfs/nisr_20060033_en.pdf	As-made 2006, professional fitness/training and original £250k general-bond term; substantially amended after 2006, including S030. Historic officeholder qualification references cannot supersede 2016 reforms. N2491_floating.doc +1
S030 B	NI Department for the Economy, S.R.2025 No.177, Insolvency Practitioners (Amendment and Transitional Provisions) Regulations (NI) 2025, regs.1, 3–6, Sch.2 substituted bond terms. PDF P0–P3, printed pp.1–4. https://www.legislation.gov.uk/nisr/2025/177/pdfs/nisr_20250177_en.pdf	Operative 9 Dec 2025 with pre-1 Jan 2027 bond/appointment saving. NI IP fraud/dishonesty security, £750k prospective general penalty sum, not consumer-money guarantee. legislation.gov.uk +1
S031 B	NI Assembly, Insolvency (Amendment) Act (NI) 2026, Part 8, s.93(1)–(6) repeal of fast-track voluntary arrangements and existing-case saving. https://www.legislation.gov.uk/nia/2026/6/part/8/data.html	Royal Assent 24 June 2026 is distinct from substantive commencement. NI s.93 commenced 16 Oct 2026 by S032. No PDF pagination for this HTML section. legislation.gov.uk
S032 B	NI Department for the Economy, S.R.2026 No.180, Insolvency (Amendment) (2026 Act) (Commencement No.1 and Transitional Provisions) Order (NI) 2026, arts.2(1)–(2)(n),(s), 3–5. https://www.legislation.gov.uk/nisr/2026/180/made/data.html	Made 15 Oct, relevant provisions in force 16 Oct 2026; other provisions expressly future or commenced for preparatory/delegated purposes only. NI, no PDF pages for HTML. legislation.gov.uk
S033 B	FCA, FCA Firm Checker, guidance for confirming permitted financial service identity. https://www.fca.org.uk/consumers/fca-firm-checker	Public official guidance accessible 26 Oct 2026; consumer read-only lookup workflow described, not performed. UK including NI. FCA
S034 B	FCA, Financial Services Register, listing types and status/permissions information. https://www.fca.org.uk/firms/financial-services-register	Official register guidance accessed 26 Oct 2026. No person/firm record was queried. Registration and authorisation classes are not interchangeable. FCA
S035 B	NI Department for the Economy, Find an insolvency practitioner, official directory search description. https://www.economy-ni.gov.uk/services/find-insolvency-practitioner	Live webpage accessed 26 Oct 2026; no search undertaken. Directory results may not by themselves establish officeholding in a particular case. Department for the Economy
S036 B	NI Department for the Economy, Statement of Insolvency Practice 3.1—Individual Voluntary Arrangements, introductory official description of IP as adviser/nominee/supervisor. https://www.economy-ni.gov.uk/publications/sip-31-individual-voluntary-arrangements	Page published 1 July 2014; page body read, linked SIP PDF not read. This supports the NI IVA role distinction only; not a full 2026 procedures/conduct statement. Department for the Economy

Captured table 11

Original headerless table; first data row retained · 26 data rows

Claim	Exact assertion; required predicate or exception; consequence	Direct source and pinpoint	Confidence / limit
C001	A person carrying on a regulated activity in the UK needs appropriate authorised or exempt status under FSMA s.19, where the statutory elements apply.	S001 s.19, S002 PERG 2.2, S003 art.4	H; exemptions/territory remain case-specific.
C002	Negotiating discharge of a credit-agreement borrower's debt for that borrower, assuming business conduct and no exclusion, falls within RAO 39D(1); the specified consumer-hire equivalent falls under 39D(2).	S003 art.39D(1)(a)–(c),(2)(a)–(c)	H for activity words; 2026 whole-chapter cutoff M.
C003	Advice about liquidation of a debt to a borrower under a credit agreement, or hirer under consumer-hire agreement, is specified in 39E(1)/(2); fact-specific advice must be distinguished from information.	S003 art.39E(1)–(2); S008 PERG17.2	H/M.
C004	Obtaining payment of certain covered obligations for a creditor, rather than counselling the debtor, invokes 39F, subject to express limitations/exclusions.	S003 art.39F(1)–(3), 39H, 39L	H/M; particular debt/actor required.
C005	Performing duties or exercising/enforcing lender/owner rights for that lender/owner invokes 39G, not merely managing the debtor's personal budget.	S003 art.39G(1)–(3)	H/M.
C006	Introductions, offers or preparatory work directed to entry into qualifying credit/hire agreements may be 36A credit broking; existing-debt referrals alone are not automatically 36A.	S003 arts.36A(1)–(4), 36B–36F	H/M; fee/exclusion distinctions preserved.
C007	Performing an act defined as providing credit-information services is a separate potential regulated activity under 89A; “credit repair” marketing alone is not a sufficient legal classification.	S003 arts.39L/72H references, 89A	M; full fact-specific 89A exclusions not closed.
C008	An agreement to carry out a specified regulated activity can itself fall within RAO 64 where its conditions apply.	S003 art.64 and adjacent exclusions	M; requires exact promised activity.
C009	Credit-related activities entered the FCA regime through the 2013 amendment order, with the principal commencement 1 Apr 2014, not the order's 2013 publication date.	S006 arts.1(2)–(6), 3–6; S007 PERG2.3.2	H.
C010	Qualifying not-for-profit bodies doing non-occasional debt adjusting, counselling or credit-information service are treated as carrying on business under business-order 3E; the occasional-only proviso limits that deeming rule.	S006 art.13, inserted 3E(1)–(4); S007 PERG2.3.2(3B)	H, constitution and frequency must be tested.
C011	Credit agreement's borrower definition concerns an individual or relevant recipient of credit; a qualifying small partnership/unincorporated body may count, an ordinary incorporated company's own debt ordinarily does not.	S003 arts.60B(3), 60L(1); S005 60B(3)	H/M; inspect organisational form and agreement.
C012	RAO 39D/39E say credit agreement, while 60B(3) differentiates regulated credit agreement; these terms cannot be interchanged.	S003 39D/E; S005 60B(3)	H text; overlap exceptions still apply.
C013	Under 60C(3) a credit agreement exceeding £25,000 wholly/predominantly for business is exempt for that chapter; 60C(5)–(6) sets declaration/rebuttal treatment.	S005 60C(1),(3),(5)–(7)	H; not a debt-advice carve-out by itself.
C014	A guarantor or third-party funder is not automatically the borrower for 39E merely by paying; a signed joint borrower can be the recipient.	S003 39E(1), 60L borrower definitions; S005 60B(3)	M—statutory-role inference; guarantee/agency specifics unresolved.
C015	Certain mortgage/home-finance overlaps are dealt with through RAO 39J and other activity classifications; security on land is not a universal 39D/39E exclusion.	S003 39J(1)–(3), 39L; S005 60C(2)	M; mortgage product and date required.
C016	39H provides role-specific lender, owner, supplier and other exclusions with limits, including the 39H(1A) qualification; a generic creditor or debt-buyer label is insufficient.	S003 39H(1)–(3), 39F/G; S005 60B(2)	H/M.
C017	“Charitable,” “free consultation” and “no debtor fee” do not themselves disapply 39D/39E: business and precise exemption tests remain necessary.	S006 art.13 / 3E; S007 PERG2.3.2–2.3.3	H, no blanket exemption.
C018	NI district council qualifies as RAO's “local authority” under art.3 and 72G excludes described local-authority acts from 39D–39G; other public bodies must establish their own basis.	S004 art.3 definition; S003 72G(1)–(3), 39L	H/M, actor identity essential.
C019	RAO 39K concerns specified barrister/solicitor acts in advocacy/litigation capacities including NI solicitor branch; general non-litigious service is not automatically excluded.	S003 39K(1)–(3)	H/M, service-specific.
C020	FSMA s.327 professional exemption requires compliance with designated-body rules, incidental/complementary professional service and financial benefit conditions, subject to 328/329 restrictions.	S001 ss.326–329, 332 as enacted; S012 PROF2.1.3–2.1.14; S013 Annex1	H FCA guidance; individual body-rule check held.
C021	RAO 72H(1)–(3) excludes stated acts as insolvency practitioner; reasonable contemplation of appointment has narrower specified 39D/39E/89A scope.	S003 72H(1)–(3), 39L; S015 CONC10.2.10G	H/M, actual appointment/capacity required.
C022	An appointed representative operates through a principal's responsibility and valid contract for eligible specified activities, not independent comprehensive authorisation.	S001 s.39; S011 SUP12	H/M, validate principal, activity eligibility and scope.
C023	The legal person carrying on in-scope debt adjusting/counselling needs its own appropriate FCA permission unless lawfully excluded/exempt/represented; permission restrictions and DMP scope matter.	S001 ss.19, 40; S003 39D/E; S014 FEES3 Annex1 CC2	H framework, actual firm permission not tested.
C024	For covered CONC10 firms, prudential requirement is the higher of £5,000 or 0.25% first £5m + 0.15% next £95m + 0.05% above, with higher-other-regime provision.	S015 10.1.1–1.2, 10.2.2–2.10	H, not compensation or segregated client money.
C025	At the 2 July 2026 pricing schedule, FEES3 CC2 restricted category 3 = £1,130 and broader category 6 £11,260 per relevant application classification.	S014 FEES3 Annex1 Part2 CC2; Annex1A	H on listed categories; combinations/actual applicant require more facts.

Captured table 12

Original headerless table; first data row retained · 14 data rows

Claim	Exact assertion; predicates, exception and consequence	Direct source/pinpoint	Confidence / limit
C026	A payment operation is within the 2017 PSRs when a specified payment service is carried on as an independent business/regular occupation and not excluded; ordinary ancillary DMP remittance is generally not classified that way in FCA PERG Q9.	S016 regs.2, 4–5, Sch.1; S017 PERG15.2 Q9	H FCA position; contracts/cash flow determinative.
C027	Independently provided money remittance may require FCA payment-institution authorisation, small-institution registration or another valid category; FSMA permission does not automatically answer that PSR test.	S016 regs.6–14, Sch.1; S017 PERG15.2 Q11–Q11B; S018	M, all exception/threshold branches not comprehensively updated.
C028	FSMA's “carried on in the UK” link includes NI; provider/consumer/medium/location fact patterns determine reach, and non-UK location is no categorical 39D/39E exemption.	S001 s.19; S002 PERG2; S010 PERG2.4; S003 art.72	M on hypothetical overseas conduct; foreign law deferred.
C029	Violation of FSMA ss.19/20/23 has statutory regulatory/criminal consequences only on proven elements and exceptions; it does not automatically extinguish creditor obligations.	S001 ss.19–29, especially s.28(9); S002 PERG2.2	H for nonautomatic effect; full remedies deferred.
C030	FCA provides public firm checker and register; valid confirmation requires matching legal person, active status, activity permission/restriction, and AR/principal where relevant.	S033 FCA checker instructions; S034 FS Register instructions; S011 SUP12	H, no particular listing checked.
C040	NI IP bond amendment increased general penalty sum to £750,000, subject to S.R.2025/177 reg.6 saving for certain pre-2027 bond/case combinations, to address specified dishonest-loss claims.	S029 Sch.2 para.3 historic £250k; S030 regs.5–6	H, not a settlement-refund promise.
C041	CONC10 applies to an NFP debt advice body if it held £1m+ client money within last 12 months or projects that level within next 12; qualifying professional-firm exception has specific 50%-income and incidental requirements.	S015 10.1.1(2), 10.1.2(1)–(3)	H, client-money meaning not fully audited.
C043	Debt-specific personalised advice must be tested against 39E; unpersonalised information may not meet its advice element. Delivery through an algorithm does not itself settle the test.	S003 39E; S008 PERG17.2; S009 PERG17.3–17.6	M; product interactions needed.
C044	Register listing, FCA authorisation or an insolvency title does not independently establish lawful contract terms, creditor assent, debt release or successful outcome.	S033–S034 register scope; S003 regulated activities; S036 IVA distinct statutory role	H logical limitation, no specific agreement assessed.
C046	S.I.2013/1881 art.60 had a restricted not-for-profit former group-licence permission route from 1 Apr 2014, only to licence-described activities; old licence alone is not present proof of permission.	S006 art.60(1)–(3); S034 current register	H on historic transition, individual present status untested.
C047	Being licensed as an NI IP does not automatically authorise unrelated debt-adjusting services outside the 72H capacity; FSMA exemption and NI officeholding are different tests.	S003 72H; S021 s.14 / 349A; S012 PROF2.1	H/M, dual activity details needed.
C049	Business-purpose exempt credit lending under 60C does not alone remove debtor-side 39D/E where the debt remains due under a “credit agreement”; other specific exclusions may still apply.	S005 60B(3), 60C(3); S003 39D/E/H/J	H on terminology; definitive case outcome held.
C050	Debt categories like tax, rent, support, rates, fines and ordinary company trade invoices do not become 39D/E credit-agreement debt solely by label, and other legal gateways may remain.	S003 39D/E; S005 60B(3); S009 PERG17	M, other product/sector law deferred.

Captured table 13

Original headerless table; first data row retained · 13 data rows

Claim	Exact assertion; predicates, exceptions and consequence	Direct source/pinpoint	Confidence / limit
C031	NI IVA is distinct statutory arrangement under NI 1989 Order Part VIII Ch.II, with statutory nominee/supervisor roles; not any private repayment negotiation.	S020 index only, Part VIII; S021 s.5, Sch.3–4; S036 IVA explanatory text	M; consolidated Order direct body access gap.
C032	An NI insolvency practitioner must be an individual, qualified/appropriately authorised under reformed 349/349A; full versus individual-only/company-only partial authorisation determines role scope.	S021 s.14(2)–(4), 349A(1)–(5); S029 reg.2/Sch.2 as amended	H for 2016 enactment; complete current RPB roster held.
C033	NI Department for the Economy supervises statutory recognition of professional bodies under reformed art.350, which authorise individual insolvency practitioners subject to training/fitness/security.	S021 ss.14–17; S029 reg.6–10, read with S030	H/M; current recognition must be verified.
C034	S.R.2025/170 removed Law Society NI as an NI insolvency RPB effective 5 Nov 2025; separate FSMA designated professional-body listing is not repealed by this instrument.	S026 arts.1–2; S028 departmental notice; S013 PROF2 Annex1	H within distinct statutes.
C035	NI Department's art.350N notice states Chartered Accountants Ireland NI insolvency RPB recognition ended 19 Feb 2025.	S027 effective-date paragraph, S026 explanatory history mentioning S.R.2025/19	M because S.R.2025/19 not itself body-read.
C036	NI DRO Official Receiver makes the statutory order; an individual “approved intermediary” under 208U(1) must have approval from a Department-designated competent authority.	S022 s.1, 208C–208E, 208U(1)–(4); S023 regs.3–10; S024	H for statutory roles, current individual designation not checked.
C037	NI 208U restricts charging debtor for activities connected to a DRO application as an approved intermediary, within the express statutory wording, not a general debt-advice-fee determination.	S022 208U(7)	H for that role only; consumer fee dossier deferred.
C038	NI bankruptcy involves NI statutory High Court/Official Receiver/trustee officeholder roles, not a generic commercial “bankruptcy adviser” licence.	S021 s.8; 1989 Order references; S029 reg.2	M, full Part IX consolidation and procedure excluded.
C039	NI 2026 s.93 abolished 1989 Order arts.237A–237G fast-track voluntary arrangement route effective 16 Oct 2026; s.93(6) preserves already-submitted specified cases.	S031 s.93(1)–(6); S032 art.2(1),(2)(n)	H, precise grandfathering predicate retained.
C042	The 2016 reform repealed NI 1989 Order article 348A and alternate authorised nominee/supervisor wording; a pre-repeal consolidated extract must not be treated as current.	S021 Sch.3 paras.4–15; Sch.4, plus s.27	H on repeal text; commencement annotation cross-check.
C045	An old NI government list of insolvency RPBs may be stale after 2025 revocations; professional-body designation and current individual licence must be checked separately.	S026–S028 revocation/effective dates, S035 directory	H as dated-list warning; no exhaustive live RPB list claim.
C048	A negotiated payment compromise is not the NI statutory IVA or DRO merely because parties call it an “arrangement”; NI statutory offices arise under their governing instrument.	S021 IVA amendments; S022 DRO statutory gateway; S036 IVA role description	H for mechanism distinction, no statement of private contract enforceability.

Captured table 14

Original headerless table; first data row retained · 24 data rows

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and exact next retrieval/question
A01 A	Does UK FSMA/RAO apply to covered NI activity? Yes, subject to regulated activity, business, nexus and exceptions.	C001; S001–S003, S010	For a given service: which conduct occurs in the UK? Obtain hypothetical activity map.
A02 A	What constitutes debtor-side negotiation? RAO 39D, distinct hire branch.	C002; S003 art.39D	Particular authority/agency contract and credit instrument.
A03 A	What constitutes debtor-specific repayment advice? RAO 39E, credit and hire branches.	C003; S003 art.39E, S008	Specific advice output and legal borrower identity.
A04 A	Is creditor-side collection the same permission? No; 39F separately defined.	C004; S003 art.39F	Creditor/collector contract and 39H predicates.
A05 A	Is administering a DMP necessarily debt administration? No; 39G lender/owner rights test.	C005; S003 art.39G	Whose rights/duties does actor exercise?
A06 A	Are introductions always credit broking? No; 36A specifies covered credit/hire introductions and exclusions.	C006; S003 arts.36A–36F	Destination product, commission and actual referral role.
A07 P	Is credit repair a separate permission? 89A potentially; precise subactivity must be established.	C007; S003 art.89A references	Open current RAO 89A/89B and read each exclusion against credit-repair example.
A08 A	Can agreeing now to perform later matter? Potentially RAO 64.	C008; S003 art.64	Exact engagement promise and whether future act is specified.
A09 A	What is “by way of business”? Statutory test plus 2001 Business Order, modified by specific activity and nonprofit provision.	C009–C010; S006 art.13, S007	Continuity, scale, commercial benefit and organisational constitution.
A10 A	Does a fee-free first meeting exempt a paid later service? No automatic exemption.	C017; S007 PERG2.3	Whole sales funnel, indirect consideration and substantive advice.
A11 A	Are charities/free providers automatically outside? No, art.3E has a non-occasional deeming rule.	C010, C017; S006, S007	Frequency; constitution; actual authorised/exempt legal capacity.
A12 A	Is an individual borrower included? Yes, for qualifying credit-agreement activity.	C011; S003 60L, S005 60B	Named borrower and underlying debt agreement.
A13 A	Do sole-trader business debts automatically escape? No; individual borrower and agreement exemptions are distinct tests.	C011–C013, C049; S003, S005	Loan amount, date, business-use declaration, 39H/J overlap.
A14 A	Which partnerships/unincorporated bodies are relevant? Statutory relevant-recipient definition, not every organisation.	C011; S003 art.60L	Number/type of partners and actual borrower.
A15 A	Are all corporate company debts covered by 39D/E? No, company-alone branch needs other authority.	C011–C012; S003, S005	Any separate individual borrowing/guarantee or other activity.
A16 P	Joint borrower, guarantor, third-party payer? Only actual statutory borrower/hirer status decides 39E; beneficiary/agent may matter for 39D.	C014; S003 39D/E, 60L	Current creditor agreement, guarantee and agency facts; reconcile each branch.
A17 A	Secured/unsecured/hire debts one category? No; hire and home-finance overlaps differ.	C002–C005, C015; S003, S005	Mortgage contract type and security instrument.
A18 A	Are exempt lending agreements necessarily excluded from advice? No; “credit” versus “regulated credit” text differs.	C012–C013, C049; S003, S005	Apply every relevant 39H/39J and specific contract exception.
A19 P	Are tax/rent/support/fines/utility bills necessarily FCA debt advice? Not merely by label.	C050; S003, S005	Test actual underlying agreement and any other sector authorisation.
A20 A	Did consumer-credit perimeter start merely at 2013 enactment? No; substantial transition on 1 Apr 2014.	C009, C046; S006	Historical firm-specific interim permission, if ever relevant.
A21 P	Is every RAO 39D–39L 2026 amendment independently accounted for? No, 2025 whole-part body and some 2026 narrower provisions read.	C002–C008; S003–S005	Retrieve accessible full amended Part II as at 26 Oct 2026, compare legislative changes after 15 Jul 2025 provision-by-provision.
A22 A	Is 2026 publication the same as commencement? No; 2026 NI Act and order have separate dated operative provisions.	C039; S031–S032	For additional 2026 sections, read each appointed commencement and saving before asserting operation.
A23 U	Are there further specialised trade/sector gateways for noncredit debt advice not captured here? Not determined.	C050; S003 scope boundary	Next narrow provider pass: classify any proposed pension, investment, mortgage, housing, tax or immigration advice against its own operative instrument.

Captured table 15

Original headerless table; first data row retained · 16 data rows

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and next question
B01 A	Paid commercial debtor-side firm: 39D/E and appropriate FCA route, not a generic debt licence.	C001–C003, C023; S001–S003, S014	Who is the contracting legal person; which permissions?
B02 A	Not-for-profit/charity/free advice: no blanket immunity; art.3E.	C010, C017; S006–S007	Is activity occasional only; which entity and authorised/exempt status?
B03 P	Government-funded or public adviser: no general “public sector” exemption established.	C018; S003 72G, S004 art.3	What is exact public body and its enabling function?
B04 A	NI district council as local authority: 72G specified exclusions.	C018; S003, S004	Is the actor the council itself or a separate subsidiary/contractor?
B05 A	Solicitor litigation/advocacy: 39K specific branch.	C019; S003 art.39K	Is actual activity advocacy/litigation?
B06 P	Solicitor/accountant non-litigious professional services: conditional FSMA s.327 and body rules.	C020; S001, S012–S013	Read current specific designated body's approved s.332 rules for the service.
B07 A	Creditor collecting own debt: 39H, regulated creditor/lender-rights branch and exceptions.	C016; S003 39H, S005 60B(2)	Original ownership and whether any work is for another lender.
B08 P	Debt buyer/acquirer: role and rights can cross 60B(2), 39F/G.	C004–C005, C016; S003, S005	Assignment, servicing, original agreement and exemption predicates.
B09 A	Independent creditor collector: creditor-side permission distinct from borrower-side counselling.	C004–C005; S003 39F/G	Exact engagement and lender/owner principal.
B10 A	Referrer/publisher/software: activity and remuneration control, not label.	C006–C008, C043; S003, S008–S009	Actual information/advice interface and referral contracts.
B11 A	Ancillary DMP payment distributor: not automatically PSR payment business.	C026; S016–S017	Service independence and fund-flow arrangements.
B12 P	Independent payment remitter: another gateway may apply.	C027; S016–S019	Current PSR authorisation/registration amendments and specific arrangement.
B13 A	Statutory IP: 72H capacity-limited and separate 349A appointment.	C021, C032, C047; S003, S021	Which individual and case capacity?
B14 A	Appointed representative: principal-based s.39/SUP12.	C022; S001, S011	Actual AR contract, principal permission and covered activity.
B15 P	Special public agency/charity undertaking only NI DRO-approved work: separate 208U authority, not universal FCA exclusion.	C036; S022–S025	Does it also give other debt advice? Check 72H/other actual exemption separately.

Captured table 16

Original headerless table; first data row retained · 17 data rows

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and next question
COV-C01 A	FCA authorisation belongs to appropriate legal person, with named activity permission.	C001, C023; S001, S014	Exact firm/entity and restricted permission.
COV-C02 A	FCA full/limited and DMP distinctions materially affect applicant classification.	C023, C025; S014 Annex1	Apply regulatory activity group and permitted restrictions to an actual business model.
COV-C03 A	AR is exemption through authorised principal/contract for eligible activities, not free-standing licence.	C022; S001 s.39, S011	Which regulated act in principal's permission and AR contract?
COV-C04 P	Exempt professional firm has designated professional body/approved rules/incidental capacity predicates.	C020; S012–S013	Read actual current NI solicitor/accountancy body permitted-activity schedule.
COV-C05 A	NI insolvency-practitioner authorisation is individual, potentially partial by company/individual scope.	C032–C033; S021 s.14	Individual licence and authorising RPB currentness.
COV-C06 A	NI DRO competent authority designation differs from individual intermediary approval.	C036; S022 208U, S023 regs.3–10	Current competent authority and individual approval status, hypothetically.
COV-C07 P	Fitness, experience, training and qualifications for NI officeholders/advisers: meaningful regulations exist, but post-2016 consolidation must be applied.	C032–C036; S021, S023, S029	Reconcile revised Article349A with amended 2006 fitness regulations; reconcile obsolete 2011 CCA licence language.
COV-C08 P	NI DRO intermediary public-liability/indemnity insurance appears in 2011 regs.8–9.	C036; S023 regs.8–9	Read 2026 revised text and ensure exact policy coverage/amount; no universal numeric PII figure adopted.
COV-C09 A	Debt-management CONC10 financial resources and £5k floor/proportional formula are distinct from compensation/client funds.	C024; S015 10.1–10.2	For a hypothetical firm, calculate relevant debts and other higher requirement.
COV-C10 A	£1m client-money threshold for certain not-for-profit bodies affects CONC10 application.	C041; S015 10.1.1	Twelve-month actual/projection and statutory “client money” treatment.
COV-C11 A	2026 FCA applicant categories 3/6 have specified prices, not customer fees.	C025; S014 Annex1/1A	Multi-activity grouping, permission limit, not-for-profit fee exception.
COV-C12 A	NI IP bond now has £750k new standard subject to express pre-2027 saving.	C040; S029–S030	Bond issue/appointment dates and whether relevant loss within cover.
COV-C13 P	Further PII, minimum liquidity, bonding or security for other actor categories cannot be assumed.	C024, C027, C036, C040; S015–S016, S023, S030	Identify exact regulated activity and source of each proposed financial safeguard; retrieve its operative schedule.
COV-C14 A	Historic 2014 consumer-credit permission route exists but is not proof of present firm authorisation.	C009, C046; S006 art.60, S034	Modern FCA register legal entity/permission, hypothetically.
COV-C15 P	FCA accountable management, fitness, competence and threshold conditions apply according to permission and firm type.	C023–C024; S001, S002, S015	Read current COND/SYSC/SMCR-specific provisions for a defined firm; no invented single named responsible-person requirement.
COV-C16 P	Payment institution may have separate initial-capital/safeguard requirements, conditional on PSR activity.	C026–C027; S016–S019	Confirm exact 2026 amended PSR Sch.3 capital and applicable provider classification; no sum transferred to an ordinary DMP firm.

Captured table 17

Original headerless table; first data row retained · 9 data rows

Row / status	Material question and answer boundary	Claims; primary sources	Missing evidence and next question
D01 A	NI lies inside UK FSMA geographic frame.	C001, C028; S001 s.19, S010	Where do particular regulated acts occur?
D02 A	Rest-of-UK provider into NI: UK FCA classification remains possible; NI statutory role separately governed.	C028, C031–C038; S010, S021–S023	Is service financial, insolvency officeholding or both?
D03 P	Foreign provider into NI via online/telephone: no automatic nonresident exemption.	C028; S003 art.72, S010 PERG2.4	Actual acts, agents, UK establishment and relevant RAO territorial exclusions.
D04 P	NI provider helping debtor abroad: NI place of carrying on business can matter; foreign regulatory permissions not resolved.	C028; S001, S010	Map acts in UK; A098 foreign state requirements separately.
D05 A	Website/telephone medium itself does not decide regulated activity.	C028, C043; S008–S010	Degree of personalised advice and who supplies it.
D06 P	Offshore affiliate, call-centre agent, introducer: actor-by-actor UK link necessary.	C006, C022, C028; S003, S010–S011	Agency/contracts, payments, attribution, actual location.
D07 P	Any specific treaty/overseas-person exemption for an identified nonstandard activity? Only if exact law allows.	C028; S003 art.72	Read exemption for the specific activity; 39D/E cannot borrow unrelated art.72 limb.
D08 D	Foreign recognition, creditor law, judgment enforcement and assets/migration.	C028 boundary; S010	A098: What foreign law governs the identified debtor/creditor/asset and recognition event?

Captured table 18

Original headerless table; first data row retained · 10 data rows

Row / status	Verification question	Claims; official sources	Missing evidence and next check
E01 A	Is legal identity more reliable than brand name? Yes for register matching.	C030; S033–S034	Precise legal entity, trading name and signing party.
E02 A	Is an FCA listing enough? No; must inspect exact permission, status and restriction.	C023, C030, C044; S033–S034	Activity-to-permission match at relevant engagement date.
E03 A	What about AR? Match AR and principal, permitted contracted activity.	C022, C030; S011, S034	Principal permission and representation contract.
E04 P	Exempt professional firm: body listing alone insufficient.	C020; S012–S013	Firm's designated-body exempt status and current rule permitted acts.
E05 A	Separate payments register class may be necessary when independently remitting.	C026–C027; S016–S018, S034	Determine payment service first, then correct FCA category.
E06 P	NI insolvency practitioner directory: useful but not complete proof.	C032–C035; S026–S028, S035	Authorising RPB, individual licence, limited capacity, actual appointment.
E07 P	NI DRO body list: organisation status does not certify each adviser.	C036; S023–S025	Linked authority roster attachment and individual approval.
E08 A	Have actual entities/people/cases been checked? No; all procedures were hypothetical.	C030, C044; S033–S035	No additional real-case lookup within authorisation.
E09 A	Does authorisation prove settlement/debt release? No.	C044; S033–S034, S036	Later contract/creditor assent and remedy dossier; outside P01.

Captured table 19

Original headerless table; first data row retained · 13 data rows

Row / status	NI gateway issue and limited finding	Claims; primary sources	Missing evidence and exact next question
F01 A	Private voluntary negotiation is not itself statutory NI IVA/DRO.	C048; S021–S022, S036	Does provider claim a specific statutory office or only consensual negotiating authority?
F02 P	NI IVA nominee/supervisor and Part VIII authority identified.	C031–C032, C042; S020–S021, S036	Obtain current amended 1989 Order 227–236 body and current NI IVA rules before procedural claims.
F03 A	NI insolvency practitioner is individual with appropriate/partial authorisation.	C032–C033; S021 s.14, S029–S030	Exact individual scope and current RPB confirmation.
F04 A	2016 repeal of alternative authorisation under 348A.	C042; S021 Sch.3/4	Verify commencement annotations if evaluating a historic appointment.
F05 P	NI DRO Official Receiver and approved intermediary/competent authority roles established.	C036–C037; S022–S025	Current approved-intermediary roster and 2011 licence-language reconciliation.
F06 P	NI bankruptcy High Court/Official Receiver/trustee boundary established, not full procedure.	C038; S021, S029	Read current 1989 Order Part IX/NI rules only in later bankruptcy pass.
F07 A	Law Society NI insolvency RPB recognition revoked 5 Nov 2025.	C034; S026, S028	Distinguish retained FSMA designated-professional function, then verify individual alternative RPB.
F08 P	Chartered Accountants Ireland NI insolvency RPB recognition revoked 19 Feb 2025.	C035; S027, plus S026 history	Retrieve and body-read S.R.2025 No.19 for direct independent enactment confirmation.
F09 P	Exhaustive current NI recognised professional bodies not established solely by old agency lists.	C033–C035, C045; S020–S021, S026–S028	Read S.R.1991 No.301 consolidated Schedule and every applicable 2022/2025 amendment.
F10 A	2026 fast-track voluntary arrangements repealed for new cases 16 Oct 2026, existing-submission saving.	C039; S031 s.93, S032 art.2(2)(n)	For historic cases only: was 237B(1) submission made before operative date? No actual case checked.
F11 A	NI IP general bond changed in 2025 with express transitional saving.	C040; S029–S030	Determine bond/appointment dates; no case, claim or insurance lookup.
F12 D	IVA/DRO/bankruptcy eligibility, procedure, distribution, discharge, tax and cost are not answered.	C031/C036/C038 boundary only; S020–S024	Later solution-specific dossier: what are current NI qualifying conditions, acts, forms and legal effects?

Captured table 20

Original headerless table; first data row retained · 13 data rows

Row / status	Coverage	Claims; sources	Remaining evidence/next question
G01 A	Paid card settlement scenario G1	C002–C003; S003	Contract, borrower and permission in any actual matter.
G02 A	Nonprofit free-adviser scenario G2	C010, C017; S006–S007	Constitution, regularity and exempt/authorised capacity.
G03 A	NI solicitor commercial settlement scenario G3	C019–C020; S003, S012–S013	Current professional-body s.332 rules and incidental-service facts.
G04 A	Insolvency practitioner selling separate DMP G4	C021, C047; S003, S021	Appointment capacity versus commercial mandate.
G05 A	NI DRO competent authority/employee G5	C036; S022–S025	Individual approval and authority scope.
G06 P	Overseas app/remote NI service G6	C028, C043; S008–S010	Full territorial and functional interaction evidence.
G07 A	Acquiring/collecting creditor G7	C004–C005, C016; S003, S005	Assignment and servicer status.
G08 A	Payment-only distributor G8	C026–C027; S016–S017	Whether independent PSR payment service exists.
G09 A	FCA fee example (£1,130/£11,260, 2026)	C025; S014	Precise applicant category, no consumer fee implied.
G10 A	CONC resources examples (£5k/£20k), formula verified	C024, C041; S015	Actual relevant-debt calculation and higher parallel requirement.
G11 A	NI practitioner bond (£750k with transition)	C040; S029–S030	Bond and appointment dates; covered loss, not assumed award.
G12 A	Unauthorised activity consequence kept conditional	C029; S001–S002	Any actual allegation would require each criminal/regulatory element and defence; remedies separate.

Captured table 21

Original headerless table; first data row retained · 15 data rows

Row / status	Deferred rule family	Exact next research question
H001 D	Consumer-paid charges	What fees may an NI debt-management/settlement provider charge a debtor, by precisely classified activity?
H002 D	Indirect provider remuneration	How are creditor commissions, lead payments, affiliated benefits and other indirect compensation treated for disclosure, conflicts and authorisation?
H003 D	Fee earning	At what legally defined event, if any, is a provider entitled to earn a fee?
H004 D	Advance-payment restrictions	Which operative FCA/other rules limit taking money before negotiations, creditor agreement or performance?
H005 D	Fee caps and calculation	Are any statutory, regulatory or professional caps applicable, to which services, with what calculation base?
H006 D	Cancellation and withdrawal	What statutory or contractual cancellation rights, cooling-off periods and notices govern each transaction channel and provider class?
H007 D	Refunds and unearned fees	What must be returned upon cancellation, nonperformance, termination, provider failure or ineffective settlement?
H008 D	Advertising and solicitation	Which current financial-promotion, advertising, cold-calling and lead-generation restrictions apply in NI to each service?
H009 D	Written contracts	Which service contracts must be in writing, and what form, signatures or electronic-record rules apply?
H010 D	Mandatory contractual terms	Which provider promises, duration, service limitations, variation and termination clauses are mandatory, prohibited or unfair?
H011 D	Pre-contract disclosures	What must the provider disclose about fees, risks, alternatives, creditor participation, client funds and status before commitment?
H012 D	Suitability and advice standards	What assessment, suitability, vulnerability and best-interests obligations apply under relevant FCA/professional rules?
H013 D	Debt-relief outcome claims	What evidence is required for claims about savings, settlement rate, time to resolution, credit effects or guarantee?
H014 D	Ongoing service and exit	What periodic statements, reviews, records, variation notices and closure steps are required during and after engagement?

Captured table 22

Original headerless table; first data row retained · 13 data rows

Row / status	Deferred rule family	Exact next research question
H015 D	Client money receipt	When is money held by a debt adviser legally “client money” under the applicable FCA regime?
H016 D	Client money segregation	What account segregation, reconciliation, identification and audit obligations apply to a specific DMP business model?
H017 D	Stand-alone payment regulation	What is the fully updated October 2026 payment-services authorisation/registration/agent and safeguard regime, including every exemption and threshold?
H018 D	Trust and insolvency ring-fencing	If a provider fails, what proprietary or trust interest, if any, exists in money held for customers?
H019 D	Payment authority and distribution	What authority is required to initiate, distribute, withhold, reverse or refund customer payments, and what records must be retained?
H020 D	Private civil remedies	What specific cause of action, standing, limitation period, damages or restitution may follow an actual provider breach?
H021 D	Regulatory breaches and enforcement	What FCA investigative powers, notices, sanctions, procedural protections and individual accountability mechanisms apply to particular contraventions?
H022 D	Consumer complaints and ombudsman	What complaints processes and Financial Ombudsman Service jurisdiction apply to each covered legal person and service?
H023 D	NI insolvency practitioner complaints	What is the current complaint allocation among NI RPB, Department, officeholder and court, including former-RPB cases?
H024 D	Compensation schemes	When, if at all, does the Financial Services Compensation Scheme or another scheme cover a failure or a dishonest loss?
H025 D	Personal data and privacy	What UK GDPR/data-protection lawful basis, retention, data-sharing and security obligations apply to debt intake and creditor negotiation records?
H026 D	Marketing/contact permissions	What consent, privacy, telephone, email, text and direct-marketing rules apply to NI debt leads, introductions and remarketing?

Captured table 23

Original headerless table; first data row retained · 12 data rows

Row / status	Deferred rule family	Exact next research question
H027 D	Credit card, overdraft and personal-loan products	What borrower rights, creditor duties and product-specific rules govern each source of debt in NI?
H028 D	Payday, BNPL and deferred-payment credit	Which 2026 commencement, temporary permission, product and grandfathering provisions apply to each agreement?
H029 D	Debt-collection conduct	What rules govern demands, communications, hardship treatment, harassment, third-party contact and collection practices?
H030 D	Validation and proof of debt	What evidence must an NI creditor/collector produce, when, and through what procedure?
H031 D	Balance and liability disputes	How does a debtor challenge balance, interest, ownership, accounting, fraud or contractual enforceability?
H032 D	Assignment and debt purchases	What notice, legal/equitable assignment, standing and debtor-defence rules govern transferred claims?
H033 D	Limitation periods	What NI limitation law and accrual date governs each credit, specialty, mortgage, tax or judgment claim?
H034 D	Acknowledgment, payment and revival	Which signed acknowledgment, partial payment, admission or other event affects a limitation defence in NI?
H035 D	Credit reference reporting	What source-specific reporting, accuracy, correction, suppression and retention rules apply?
H036 D	Credit score and future borrowing	What documented, qualified credit effects may follow each action, without promising score movement or recovery?
H037 D	Out-of-court creditor rights	What set-off, lien, acceleration, demand and account-closure rights arise under each creditor agreement and NI law?

Captured table 24

Original headerless table; first data row retained · 20 data rows

Row / status	Deferred rule family	Exact next research question
H038 D	Court jurisdiction and claims	Which NI court or statutory forum hears the identified debt claim, and under which jurisdictional rules?
H039 D	Service of process	What are the applicable NI service methods, substituted service, cross-border service and proof requirements?
H040 D	Default and response	What actual NI procedural steps and legally operative deadlines arise after a properly served claim?
H041 D	Judgment formation	What proof and hearings are required for default, summary or contested judgment?
H042 D	Set-aside and appeal	On what grounds and under what procedure can a debtor challenge or reopen a judgment or order?
H043 D	Enforcement mechanisms	What NI enforcement office, attachment, seizure, instalment, registration and creditor-priority powers exist?
H044 D	Income/property protection	What NI exemptions or protections apply to wages, household goods, benefits, pensions and property?
H045 D	Bank accounts and third-party money	What attachment, set-off or other enforcement mechanisms may reach deposits or funds held for another person?
H046 D	Secured and mortgage debt	How do NI land charges, mortgage regulation, secured arrears and redemption interact?
H047 D	Mortgage enforcement/repossession	What NI procedure governs possession, sale, deficiency and borrower protections?
H048 D	Vehicles and hire purchase	What recovery, repossession, hire termination and secured vehicle deficiency rules govern NI agreements?
H049 D	Rent and housing	What tenancy-arrears, eviction, social-housing and housing-support rules apply in NI?
H050 D	Medical and care bills	What NI health, private treatment, care contribution and related collection rules govern the obligation?
H051 D	Utilities and telecommunications	What NI electricity, gas, water, telecom, disconnection, metering and arrears protections apply?
H052 D	Family maintenance and support	What NI child-maintenance, family-support and related enforcement priorities apply?
H053 D	Fines and criminal financial orders	Which NI criminal-court or statutory collection procedures govern fines, compensation and penalties?
H054 D	Tax, rates and other government debt	What HMRC, NI rates, overpayment recovery and government-creditor powers apply to each liability?
H055 D	Priority and nonpriority sorting	What legally supported criteria determine which NI debts have more urgent consequences or priority?
H056 D	Public assistance and free support	Which current NI public benefits, emergency assistance, housing support, debt-advice services and eligibility requirements exist?

Captured table 25

Original headerless table; first data row retained · 14 data rows

Row / status	Deferred rule family	Exact next research question
H057 D	NI IVA complete procedure	What are the current NI IVA proposal, nominee, filing, creditor-decision, modification, supervision and termination rules?
H058 D	NI DRO complete procedure	What are current NI DRO eligibility, excluded debts, assets, income, applications, reviews, moratorium and discharge rules?
H059 D	NI bankruptcy complete procedure	What are the current NI petition, adjudication, trustee, estate administration, restrictions and discharge rules?
H060 D	Other NI statutory debt mechanisms	Which administration orders, compositions, debt remedies or sector-specific arrangements exist independently of IVA/DRO/bankruptcy?
H061 D	Statutory filing forms and costs	Which exact NI court/agency forms, filing charges, professional expenses and cost allocations apply at their effective dates?
H062 D	Distribution, discharge, surviving debt and tax	Which liabilities remain, how are proceeds distributed, when does discharge occur and what tax consequences follow?
H063 D	A098 foreign exchange and currency	Which currency governs each obligation, exchange conversion, payment, settlement and court calculation?
H064 D	A098 foreign contracts and governing law	Which contractual choice-of-law and mandatory protection rules determine rights under an international debt contract?
H065 D	A098 cross-border insolvency	When and how may an NI insolvency procedure be recognised abroad, or a foreign process be recognised in NI?
H066 D	A098 foreign judgments	Under what statutory/treaty/common-law route can a foreign judgment be recognised or enforced in NI, and vice versa?
H067 D	A098 relocation and offshore assets	How do change of residence, overseas income, assets, creditors and foreign collection affect rights and jurisdiction?
H068 D	Local, sector and professional overlaps	What additional NI consumer, solicitor, accountant, financial-promotion, property, mortgage, tax or contractual duties apply to a precisely identified non-gateway issue?
H069 X	All other countries and UK local regimes	Those are not adopted here. What separate jurisdiction-specific authorisation and solution rules apply if another jurisdiction is independently assigned?

Captured table 26

Original headerless table; first data row retained · 13 data rows

Required deliverable	Visible result
Primary browsing/body reads	Yes, UK Acts/SIs, FCA Handbook, NI Acts/SRs and Department pages; precise failures and limited attachments identified
Source register	36 numbered S001–S036, direct literal URLs, provisions, applicable dates, jurisdiction, read status and PDF indices where relevant
Atomic claim register	50 numbered C001–C050, with scoped predicates, exclusions, consequence, primary-source pinpoint and confidence
A–G coverage	95 rows
H deferred inventory	69 rows
Total visible coverage rows	164
Four or more scenarios	Eight bounded hypotheticals, each containing facts, tests, responsible gateway, missing facts, adverse branch and verification documents
At least two sourced quantitative examples	FCA 2026 application-category charges, two CONC10 computations, NI 2025 IP bond and 2027 saving
Actual person/provider/consumer/firm verification	None
Publication, external contact, filing, purchase, website or file alteration	None
Reliance on failed/unreviewed other-country research	None
Independent second-person review or all-law certification	None claimed

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4 pending corrections

This dated research component contains identified issues. Read the correction panel before relying on its affected passages or tables. Other findings retain their own evidence limits.

C_NI-P01-C001 Saved research record

A person carrying on a regulated activity in the UK needs appropriate authorised or exempt status under FSMA s.19, where the statutory elements apply.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C001
Direct source and pinpoint: S001 s.19, S002 PERG 2.2, S003 art.4
Confidence / limit: H; exemptions/territory remain case-specific.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": ["C_NI-P01-S001", "C_NI-P01-S002"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C002 Saved research record

Negotiating discharge of a credit-agreement borrower's debt for that borrower, assuming business conduct and no exclusion, falls within RAO 39D(1); the specified consumer-hire equivalent falls under 39D(2).

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C002
Direct source and pinpoint: S003 art.39D(1)(a)–(c),(2)(a)–(c)
Confidence / limit: H for activity words; 2026 whole-chapter cutoff M.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C003 Saved research record

Advice about liquidation of a debt to a borrower under a credit agreement, or hirer under consumer-hire agreement, is specified in 39E(1)/(2); fact-specific advice must be distinguished from information.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C003
Direct source and pinpoint: S003 art.39E(1)–(2); S008 PERG17.2
Confidence / limit: H/M.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S008"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C004 Saved research record

Obtaining payment of certain covered obligations for a creditor, rather than counselling the debtor, invokes 39F, subject to express limitations/exclusions.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C004
Direct source and pinpoint: S003 art.39F(1)–(3), 39H, 39L
Confidence / limit: H/M; particular debt/actor required.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C005 Saved research record

Performing duties or exercising/enforcing lender/owner rights for that lender/owner invokes 39G, not merely managing the debtor's personal budget.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C005
Direct source and pinpoint: S003 art.39G(1)–(3)
Confidence / limit: H/M.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C006 Saved research record

Introductions, offers or preparatory work directed to entry into qualifying credit/hire agreements may be 36A credit broking; existing-debt referrals alone are not automatically 36A.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C006
Direct source and pinpoint: S003 arts.36A(1)–(4), 36B–36F
Confidence / limit: H/M; fee/exclusion distinctions preserved.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C007 Saved research record

Performing an act defined as providing credit-information services is a separate potential regulated activity under 89A; “credit repair” marketing alone is not a sufficient legal classification.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C007
Direct source and pinpoint: S003 arts.39L/72H references, 89A
Confidence / limit: M; full fact-specific 89A exclusions not closed.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C008 Saved research record

An agreement to carry out a specified regulated activity can itself fall within RAO 64 where its conditions apply.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C008
Direct source and pinpoint: S003 art.64 and adjacent exclusions
Confidence / limit: M; requires exact promised activity.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C009 Saved research record

Credit-related activities entered the FCA regime through the 2013 amendment order, with the principal commencement 1 Apr 2014, not the order's 2013 publication date.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C009
Direct source and pinpoint: S006 arts.1(2)–(6), 3–6; S007 PERG2.3.2
Confidence / limit: H.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S007"], "not_newly_reopened_source_ids": ["C_NI-P01-S006"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C010 Saved research record

Qualifying not-for-profit bodies doing non-occasional debt adjusting, counselling or credit-information service are treated as carrying on business under business-order 3E; the occasional-only proviso limits that deeming rule.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C010
Direct source and pinpoint: S006 art.13, inserted 3E(1)–(4); S007 PERG2.3.2(3B)
Confidence / limit: H, constitution and frequency must be tested.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S007"], "not_newly_reopened_source_ids": ["C_NI-P01-S006"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C011 Recorded correction or qualification applies

Credit agreement's borrower definition concerns an individual or relevant recipient of credit; a qualifying small partnership/unincorporated body may count, an ordinary incorporated company's own debt ordinarily does not.

Recorded check status: revision or qualification required UNSENT

Claim: C011
Direct source and pinpoint: S003 arts.60B(3), 60L(1); S005 60B(3)
Confidence / limit: H/M; inspect organisational form and agreement.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": ["C_NI-P01-Q001"], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S005"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C012 Saved research record

RAO 39D/39E say credit agreement, while 60B(3) differentiates regulated credit agreement; these terms cannot be interchanged.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C012
Direct source and pinpoint: S003 39D/E; S005 60B(3)
Confidence / limit: H text; overlap exceptions still apply.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S005"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C013 Saved research record

Under 60C(3) a credit agreement exceeding £25,000 wholly/predominantly for business is exempt for that chapter; 60C(5)–(6) sets declaration/rebuttal treatment.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C013
Direct source and pinpoint: S005 60C(1),(3),(5)–(7)
Confidence / limit: H; not a debt-advice carve-out by itself.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S005"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C014 Saved research record

A guarantor or third-party funder is not automatically the borrower for 39E merely by paying; a signed joint borrower can be the recipient.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C014
Direct source and pinpoint: S003 39E(1), 60L borrower definitions; S005 60B(3)
Confidence / limit: M—statutory-role inference; guarantee/agency specifics unresolved.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S005"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C015 Saved research record

Certain mortgage/home-finance overlaps are dealt with through RAO 39J and other activity classifications; security on land is not a universal 39D/39E exclusion.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C015
Direct source and pinpoint: S003 39J(1)–(3), 39L; S005 60C(2)
Confidence / limit: M; mortgage product and date required.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S005"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C016 Saved research record

39H provides role-specific lender, owner, supplier and other exclusions with limits, including the 39H(1A) qualification; a generic creditor or debt-buyer label is insufficient.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C016
Direct source and pinpoint: S003 39H(1)–(3), 39F/G; S005 60B(2)
Confidence / limit: H/M.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S005"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C017 Saved research record

“Charitable,” “free consultation” and “no debtor fee” do not themselves disapply 39D/39E: business and precise exemption tests remain necessary.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C017
Direct source and pinpoint: S006 art.13 / 3E; S007 PERG2.3.2–2.3.3
Confidence / limit: H, no blanket exemption.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S007"], "not_newly_reopened_source_ids": ["C_NI-P01-S006"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C018 Saved research record

NI district council qualifies as RAO's “local authority” under art.3 and 72G excludes described local-authority acts from 39D–39G; other public bodies must establish their own basis.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C018
Direct source and pinpoint: S004 art.3 definition; S003 72G(1)–(3), 39L
Confidence / limit: H/M, actor identity essential.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S004", "C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C019 Saved research record

RAO 39K concerns specified barrister/solicitor acts in advocacy/litigation capacities including NI solicitor branch; general non-litigious service is not automatically excluded.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C019
Direct source and pinpoint: S003 39K(1)–(3)
Confidence / limit: H/M, service-specific.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C020 Saved research record

FSMA s.327 professional exemption requires compliance with designated-body rules, incidental/complementary professional service and financial benefit conditions, subject to 328/329 restrictions.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C020
Direct source and pinpoint: S001 ss.326–329, 332 as enacted; S012 PROF2.1.3–2.1.14; S013 Annex1
Confidence / limit: H FCA guidance; individual body-rule check held.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S012", "C_NI-P01-S013"], "not_newly_reopened_source_ids": ["C_NI-P01-S001"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C021 Saved research record

RAO 72H(1)–(3) excludes stated acts as insolvency practitioner; reasonable contemplation of appointment has narrower specified 39D/39E/89A scope.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C021
Direct source and pinpoint: S003 72H(1)–(3), 39L; S015 CONC10.2.10G
Confidence / limit: H/M, actual appointment/capacity required.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S015"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C022 Saved research record

An appointed representative operates through a principal's responsibility and valid contract for eligible specified activities, not independent comprehensive authorisation.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C022
Direct source and pinpoint: S001 s.39; S011 SUP12
Confidence / limit: H/M, validate principal, activity eligibility and scope.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S011"], "not_newly_reopened_source_ids": ["C_NI-P01-S001"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C023 Saved research record

The legal person carrying on in-scope debt adjusting/counselling needs its own appropriate FCA permission unless lawfully excluded/exempt/represented; permission restrictions and DMP scope matter.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C023
Direct source and pinpoint: S001 ss.19, 40; S003 39D/E; S014 FEES3 Annex1 CC2
Confidence / limit: H framework, actual firm permission not tested.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S014"], "not_newly_reopened_source_ids": ["C_NI-P01-S001"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C024 Recorded correction or qualification applies

For covered CONC10 firms, prudential requirement is the higher of £5,000 or 0.25% first £5m + 0.15% next £95m + 0.05% above, with higher-other-regime provision.

Recorded check status: revision or qualification required UNSENT

Claim: C024
Direct source and pinpoint: S015 10.1.1–1.2, 10.2.2–2.10
Confidence / limit: H, not compensation or segregated client money.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": ["C_NI-P01-Q003"], "fresh_selected_source_ids": ["C_NI-P01-S015"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C025 Recorded correction or qualification applies

At the 2 July 2026 pricing schedule, FEES3 CC2 restricted category 3 = £1,130 and broader category 6 £11,260 per relevant application classification.

Recorded check status: revision or qualification required UNSENT

Claim: C025
Direct source and pinpoint: S014 FEES3 Annex1 Part2 CC2; Annex1A
Confidence / limit: H on listed categories; combinations/actual applicant require more facts.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": ["C_NI-P01-Q002"], "fresh_selected_source_ids": ["C_NI-P01-S014"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C026 Saved research record

A payment operation is within the 2017 PSRs when a specified payment service is carried on as an independent business/regular occupation and not excluded; ordinary ancillary DMP remittance is generally not classified that way in FCA PERG Q9.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C026
Direct source/pinpoint: S016 regs.2, 4–5, Sch.1; S017 PERG15.2 Q9
Confidence / limit: H FCA position; contracts/cash flow determinative.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S017"], "not_newly_reopened_source_ids": ["C_NI-P01-S016"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C027 Saved research record

Independently provided money remittance may require FCA payment-institution authorisation, small-institution registration or another valid category; FSMA permission does not automatically answer that PSR test.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C027
Direct source/pinpoint: S016 regs.6–14, Sch.1; S017 PERG15.2 Q11–Q11B; S018
Confidence / limit: M, all exception/threshold branches not comprehensively updated.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S017"], "not_newly_reopened_source_ids": ["C_NI-P01-S016", "C_NI-P01-S018"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C028 Saved research record

FSMA's “carried on in the UK” link includes NI; provider/consumer/medium/location fact patterns determine reach, and non-UK location is no categorical 39D/39E exemption.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C028
Direct source/pinpoint: S001 s.19; S002 PERG2; S010 PERG2.4; S003 art.72
Confidence / limit: M on hypothetical overseas conduct; foreign law deferred.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S010", "C_NI-P01-S003"], "not_newly_reopened_source_ids": ["C_NI-P01-S001", "C_NI-P01-S002"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C029 Saved research record

Violation of FSMA ss.19/20/23 has statutory regulatory/criminal consequences only on proven elements and exceptions; it does not automatically extinguish creditor obligations.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C029
Direct source/pinpoint: S001 ss.19–29, especially s.28(9); S002 PERG2.2
Confidence / limit: H for nonautomatic effect; full remedies deferred.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": [], "not_newly_reopened_source_ids": ["C_NI-P01-S001", "C_NI-P01-S002"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C030 Saved research record

FCA provides public firm checker and register; valid confirmation requires matching legal person, active status, activity permission/restriction, and AR/principal where relevant.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C030
Direct source/pinpoint: S033 FCA checker instructions; S034 FS Register instructions; S011 SUP12
Confidence / limit: H, no particular listing checked.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S033", "C_NI-P01-S034", "C_NI-P01-S011"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C040 Saved research record

NI IP bond amendment increased general penalty sum to £750,000, subject to S.R.2025/177 reg.6 saving for certain pre-2027 bond/case combinations, to address specified dishonest-loss claims.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C040
Direct source/pinpoint: S029 Sch.2 para.3 historic £250k; S030 regs.5–6
Confidence / limit: H, not a settlement-refund promise.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S030"], "not_newly_reopened_source_ids": ["C_NI-P01-S029"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C041 Recorded correction or qualification applies

CONC10 applies to an NFP debt advice body if it held £1m+ client money within last 12 months or projects that level within next 12; qualifying professional-firm exception has specific 50%-income and incidental requirements.

Recorded check status: revision or qualification required UNSENT

Claim: C041
Direct source/pinpoint: S015 10.1.1(2), 10.1.2(1)–(3)
Confidence / limit: H, client-money meaning not fully audited.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": ["C_NI-P01-Q003"], "fresh_selected_source_ids": ["C_NI-P01-S015"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C043 Saved research record

Debt-specific personalised advice must be tested against 39E; unpersonalised information may not meet its advice element. Delivery through an algorithm does not itself settle the test.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C043
Direct source/pinpoint: S003 39E; S008 PERG17.2; S009 PERG17.3–17.6
Confidence / limit: M; product interactions needed.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S008"], "not_newly_reopened_source_ids": ["C_NI-P01-S009"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C044 Saved research record

Register listing, FCA authorisation or an insolvency title does not independently establish lawful contract terms, creditor assent, debt release or successful outcome.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C044
Direct source/pinpoint: S033–S034 register scope; S003 regulated activities; S036 IVA distinct statutory role
Confidence / limit: H logical limitation, no specific agreement assessed.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S033", "C_NI-P01-S034", "C_NI-P01-S003", "C_NI-P01-S036"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C046 Saved research record

S.I.2013/1881 art.60 had a restricted not-for-profit former group-licence permission route from 1 Apr 2014, only to licence-described activities; old licence alone is not present proof of permission.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C046
Direct source/pinpoint: S006 art.60(1)–(3); S034 current register
Confidence / limit: H on historic transition, individual present status untested.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S034"], "not_newly_reopened_source_ids": ["C_NI-P01-S006"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C047 Saved research record

Being licensed as an NI IP does not automatically authorise unrelated debt-adjusting services outside the 72H capacity; FSMA exemption and NI officeholding are different tests.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C047
Direct source/pinpoint: S003 72H; S021 s.14 / 349A; S012 PROF2.1
Confidence / limit: H/M, dual activity details needed.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S021", "C_NI-P01-S012"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C049 Saved research record

Business-purpose exempt credit lending under 60C does not alone remove debtor-side 39D/E where the debt remains due under a “credit agreement”; other specific exclusions may still apply.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C049
Direct source/pinpoint: S005 60B(3), 60C(3); S003 39D/E/H/J
Confidence / limit: H on terminology; definitive case outcome held.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S005", "C_NI-P01-S003"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C050 Saved research record

Debt categories like tax, rent, support, rates, fines and ordinary company trade invoices do not become 39D/E credit-agreement debt solely by label, and other legal gateways may remain.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C050
Direct source/pinpoint: S003 39D/E; S005 60B(3); S009 PERG17
Confidence / limit: M, other product/sector law deferred.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S003", "C_NI-P01-S005"], "not_newly_reopened_source_ids": ["C_NI-P01-S009"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C031 Saved research record

NI IVA is distinct statutory arrangement under NI 1989 Order Part VIII Ch.II, with statutory nominee/supervisor roles; not any private repayment negotiation.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C031
Direct source/pinpoint: S020 index only, Part VIII; S021 s.5, Sch.3–4; S036 IVA explanatory text
Confidence / limit: M; consolidated Order direct body access gap.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S021", "C_NI-P01-S036"], "not_newly_reopened_source_ids": ["C_NI-P01-S020"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C032 Recorded correction or qualification applies

An NI insolvency practitioner must be an individual, qualified/appropriately authorised under reformed 349/349A; full versus individual-only/company-only partial authorisation determines role scope.

Recorded check status: revision or qualification required UNSENT

Claim: C032
Direct source/pinpoint: S021 s.14(2)–(4), 349A(1)–(5); S029 reg.2/Sch.2 as amended
Confidence / limit: H for 2016 enactment; complete current RPB roster held.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": ["C_NI-P01-Q004"], "fresh_selected_source_ids": ["C_NI-P01-S021"], "not_newly_reopened_source_ids": ["C_NI-P01-S029"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C033 Recorded correction or qualification applies

NI Department for the Economy supervises statutory recognition of professional bodies under reformed art.350, which authorise individual insolvency practitioners subject to training/fitness/security.

Recorded check status: revision or qualification required UNSENT

Claim: C033
Direct source/pinpoint: S021 ss.14–17; S029 reg.6–10, read with S030
Confidence / limit: H/M; current recognition must be verified.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": ["C_NI-P01-Q004"], "fresh_selected_source_ids": ["C_NI-P01-S021", "C_NI-P01-S030"], "not_newly_reopened_source_ids": ["C_NI-P01-S029"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C034 Saved research record

S.R.2025/170 removed Law Society NI as an NI insolvency RPB effective 5 Nov 2025; separate FSMA designated professional-body listing is not repealed by this instrument.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C034
Direct source/pinpoint: S026 arts.1–2; S028 departmental notice; S013 PROF2 Annex1
Confidence / limit: H within distinct statutes.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S026", "C_NI-P01-S013"], "not_newly_reopened_source_ids": ["C_NI-P01-S028"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C035 Saved research record

NI Department's art.350N notice states Chartered Accountants Ireland NI insolvency RPB recognition ended 19 Feb 2025.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C035
Direct source/pinpoint: S027 effective-date paragraph, S026 explanatory history mentioning S.R.2025/19
Confidence / limit: M because S.R.2025/19 not itself body-read.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S027", "C_NI-P01-S026"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C036 Saved research record

NI DRO Official Receiver makes the statutory order; an individual “approved intermediary” under 208U(1) must have approval from a Department-designated competent authority.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C036
Direct source/pinpoint: S022 s.1, 208C–208E, 208U(1)–(4); S023 regs.3–10; S024
Confidence / limit: H for statutory roles, current individual designation not checked.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S022", "C_NI-P01-S024"], "not_newly_reopened_source_ids": ["C_NI-P01-S023"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C037 Saved research record

NI 208U restricts charging debtor for activities connected to a DRO application as an approved intermediary, within the express statutory wording, not a general debt-advice-fee determination.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C037
Direct source/pinpoint: S022 208U(7)
Confidence / limit: H for that role only; consumer fee dossier deferred.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S022"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C038 Saved research record

NI bankruptcy involves NI statutory High Court/Official Receiver/trustee officeholder roles, not a generic commercial “bankruptcy adviser” licence.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C038
Direct source/pinpoint: S021 s.8; 1989 Order references; S029 reg.2
Confidence / limit: M, full Part IX consolidation and procedure excluded.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S021"], "not_newly_reopened_source_ids": ["C_NI-P01-S029"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C039 Saved research record

NI 2026 s.93 abolished 1989 Order arts.237A–237G fast-track voluntary arrangement route effective 16 Oct 2026; s.93(6) preserves already-submitted specified cases.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C039
Direct source/pinpoint: S031 s.93(1)–(6); S032 art.2(1),(2)(n)
Confidence / limit: H, precise grandfathering predicate retained.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S031", "C_NI-P01-S032"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C042 Saved research record

The 2016 reform repealed NI 1989 Order article 348A and alternate authorised nominee/supervisor wording; a pre-repeal consolidated extract must not be treated as current.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C042
Direct source/pinpoint: S021 Sch.3 paras.4–15; Sch.4, plus s.27
Confidence / limit: H on repeal text; commencement annotation cross-check.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S021"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C045 Saved research record

An old NI government list of insolvency RPBs may be stale after 2025 revocations; professional-body designation and current individual licence must be checked separately.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C045
Direct source/pinpoint: S026–S028 revocation/effective dates, S035 directory
Confidence / limit: H as dated-list warning; no exhaustive live RPB list claim.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S026", "C_NI-P01-S027", "C_NI-P01-S035"], "not_newly_reopened_source_ids": ["C_NI-P01-S028"], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

C_NI-P01-C048 Saved research record

A negotiated payment compromise is not the NI statutory IVA or DRO merely because parties call it an “arrangement”; NI statutory offices arise under their governing instrument.

Recorded check status: scoped reconciliation with unread source and application holds

Claim: C048
Direct source/pinpoint: S021 IVA amendments; S022 DRO statutory gateway; S036 IVA role description
Confidence / limit: H for mechanism distinction, no statement of private contract enforceability.

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "finding_ids": [], "fresh_selected_source_ids": ["C_NI-P01-S021", "C_NI-P01-S022", "C_NI-P01-S036"], "not_newly_reopened_source_ids": [], "scope": "Originalclaimreadandreconciled;selectedsourceevidenceonly. Aselectedsourcereaddoesnotverifyeverycitedprovisionorentireclaim. Source-specificboundsandholdsgovern.", "all_claim_or_currentness_acceptance": false, "independent_review": false}

Sources, pinpoints and access limits

Keep the source version, actual read extent and jurisdiction with the proposition. A link or researcher access claim is not a substitute for an operative primary passage.

Search this report’s sources

C_NI-P01-S001 Saved research record

UK Parliament, Financial Services and Markets Act 2000, original enacted PDF; ss.19–23, 26–29, 39–40, 326–327 and 332. PDF P27–P32, corresponding original printed pp.8–13 for main prohibitions/remedies; P36–P37, printed pp.17–18 for representative/application route. https://www.legislation.gov.uk/ukpga/2000/8/pdfs/ukpga_20000008_en.pdf

Recorded check status: not newly reopened original hold retained

ID / status: S001 B
Version/effect; actor, debt and jurisdiction limits: As enacted 2000 only, not a reliable modern consolidation. UK including NI, persons conducting regulated activities. Used with current FCA guidance/amending law; original statutory wording is not asserted unchanged in all respects. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/ukpga/2000/8/pdfs/ukpga_20000008_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S002 Saved research record

FCA, PERG 2—Authorisation and regulated activities, especially 2.2 prohibition/permission and 2.4, 2.8–2.11 scope/exemption context. https://handbook.fca.org.uk/handbook/perg2?timeline=true

Recorded check status: not newly reopened original hold retained

ID / status: S002 B
Version/effect; actor, debt and jurisdiction limits: Current FCA Handbook display accessed 26 Oct 2026; relevant interface shows changes through 16 Sept 2026. Guidance (G), UK regulated activities and NI nexus, not a statutory substitute. PERG 2 Authorisation and regulated activities
Direct source URLs: https://handbook.fca.org.uk/handbook/perg2?timeline=true

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S003 Saved research record

UK Treasury, Regulated Activities Order 2001, Part II arts.4, 36A, 39D–39L, 60-series references, 64, 72, 72G, 72H, 89A references, detailed exceptions/annotations. https://www.legislation.gov.uk/uksi/2001/544/part/II/2025-07-15/data.html

Recorded check status: selected primary read with limits

ID / status: S003 B
Version/effect; actor, debt and jurisdiction limits: Official 15 July 2025 point-in-time consolidated body. UK except express geographic limits; credit agreements/hire and regulated services. July–Oct 2026 Part II whole-part consolidation was unavailable, so amendment completeness after that date is held. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/uksi/2001/544/part/II/2025-07-15/data.html

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R001", "scope": "Selected general article4;36A and selected36B–E; complete selected39D/E/F/G; partial39H,39I,39K;39L references; complete60L relevant-recipient definition;72H IP and reasonable-contemplation exclusions. No complete36F/39J/39K(3)/64/72G/89A or current whole-RAO audit.", "version_and_limits": "Explicit15July2025 PartII version, not current26/29October2026 consolidation. NI/EWS geographical amendment annotations retained; struck/scope-tagged wording not silently universalised.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S004 Saved research record

UK Treasury, same RAO, article 3 interpretation, including NI local authority and insolvency-practitioner cross-references. https://www.legislation.gov.uk/uksi/2001/544/article/3/2026-02-25/data.html

Recorded check status: selected primary read with limits

ID / status: S004 B
Version/effect; actor, debt and jurisdiction limits: 25 Feb 2026 point-in-time body, UK/NI definition branch; does not certify all changes after selected date. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/uksi/2001/544/article/3/2026-02-25/data.html

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R002", "scope": "Article3 acting-IP definition, firm attribution and local-authority geographic branches including NI district council. This does not independently close72G or all public-body exclusions.", "version_and_limits": "Explicit25February2026 version; not whole instrument or amendment chain.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S005 Saved research record

UK Treasury, same RAO Part II Ch.14A, arts.60B and 60C(1)–(8), credit/regulated credit and business-purpose exemptions. https://www.legislation.gov.uk/uksi/2001/544/part/II/chapter/14A/crossheading/the-activities/2026-07-15/data.html

Recorded check status: selected primary read with limits

ID / status: S005 B
Version/effect; actor, debt and jurisdiction limits: 15 July 2026 point-in-time body, individual/relevant recipient of credit; distinguishes borrower and lender permissions from debt-counselling activities. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/uksi/2001/544/part/II/chapter/14A/crossheading/the-activities/2026-07-15/data.html

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R003", "scope": "Selected60B activity and credit/regulated-credit definitions plus visible amendment annotations. No full60C business exemption or complete geographic/currentness reconciliation adopted.", "version_and_limits": "Explicit15July2026 narrow crossheading; NI versus EWS annotations matter. No current wholeRAO read.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S006 Saved research record

UK Treasury, S.I.2013/1881, Financial Services and Markets Act 2000 (Regulated Activities) (Amendment) (No.2) Order 2013: art.1(2)–(6), arts.3–5, art.13 inserting business-order art.3E, art.60 grandfathering. PDF P0–P3 printed pp.1–4; P31–P32 printed pp.32–33; P68 printed p.69. https://www.legislation.gov.uk/uksi/2013/1881/pdfs/uksi_20131881_en.pdf

Recorded check status: not newly reopened original hold retained

ID / status: S006 B
Version/effect; actor, debt and jurisdiction limits: As-made enactment, central operative date 1 April 2014 subject to preparatory/transitional commencement. Historical group-licence provisions not general 2026 permission. UK including NI. SI20130726rvsdRAONo2130725
Direct source URLs: https://www.legislation.gov.uk/uksi/2013/1881/pdfs/uksi_20131881_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S007 Saved research record

FCA, PERG 2.3.1–2.3.3 “The business element”; nonprofit art.3E, occasional business and case factors. https://handbook.fca.org.uk/handbook/perg2/perg2s3

Recorded check status: selected primary read with limits

ID / status: S007 B
Version/effect; actor, debt and jurisdiction limits: FCA G, current displayed version last updated 16 Sept 2026, future version indicated for 2027 (not yet operative). UK covered actors. PERG 2.3 The business element
Direct source URLs: https://handbook.fca.org.uk/handbook/perg2/perg2s3

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R004", "scope": "Selected business-test guidance excerpt only, not full article3E or fullPERG2.3. Original occasional-only/nonprofit and2014 transition source remains partially unreopened.", "version_and_limits": "Current returned FCA page excerpt, sparse selected read. Underlying2013amending body not newly reopened.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S008 Saved research record

FCA, PERG 17.2 basic debt-counselling elements, borrower, particular credit debt and advice. https://handbook.fca.org.uk/handbook/perg17/perg17s2

Recorded check status: selected primary read with limits

ID / status: S008 B
Version/effect; actor, debt and jurisdiction limits: FCA G, current interface viewed; UK including NI, particular credit/hire debt advice. handbook.fca.org.uk
Direct source URLs: https://handbook.fca.org.uk/handbook/perg17/perg17s2

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R005", "scope": "Material PERG17.2 advice versus information gateway; not all17.3–17.6, judicial interpretation or algorithm/product-specific test.", "version_and_limits": "FCA guidance as returned29October2026; current legislative reach/application not fully closed.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S009 Saved research record

FCA, PERG 17 consolidated consumer-credit debt-counselling questions and examples, general information versus borrower-specific assessment. https://handbook.fca.org.uk/handbook/perg17

Recorded check status: not newly reopened original hold retained

ID / status: S009 B
Version/effect; actor, debt and jurisdiction limits: FCA G, 26 Oct 2026 access; UK covered debt advice. Guidance examples cannot settle unspecified software behaviour. PERG 17 Consumer credit debt counselling
Direct source URLs: https://handbook.fca.org.uk/handbook/perg17

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S010 Saved research record

FCA, PERG 2.4, link between regulated activities and the UK. https://handbook.fca.org.uk/handbook/perg2/perg2s4?timeline=true

Recorded check status: selected primary read with limits

ID / status: S010 B
Version/effect; actor, debt and jurisdiction limits: FCA G, displayed current at access; UK territorial operation, overseas and NI services. No foreign-state licensing certification. handbook.fca.org.uk
Direct source URLs: https://handbook.fca.org.uk/handbook/perg2/perg2s4?timeline=true

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R006", "scope": "Selected UK territorial gateway explanation. No overseas-fact scenario, full exclusions or foreign-law outcome assessed.", "version_and_limits": "Current returned guidance excerpt; foreign/regional/application holds retained.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S011 Saved research record

FCA, SUP 12, appointed representatives: responsibilities, contractual scope, oversight and relevant registration. https://handbook.fca.org.uk/handbook/sup12

Recorded check status: selected primary read with limits

ID / status: S011 B
Version/effect; actor, debt and jurisdiction limits: Current FCA Handbook section as accessed; R/G depending provision. AR/principal route for activities lawfully eligible; UK including NI. SUP 12 Appointed representatives
Direct source URLs: https://handbook.fca.org.uk/handbook/sup12

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R007", "scope": "Selected AR eligibility/credit-activity and principal-agreement excerpts. No whole SUP12, complete contract conditions or actual principal/AR register result.", "version_and_limits": "FCA handbook selected excerpts; full current FSMA39 and actual contract untested.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S012 Saved research record

FCA, PROF 2.1.1–2.1.14, FSMA ss.326–329, 332 professional-firm gateway and restrictions. https://handbook.fca.org.uk/handbook/prof2/prof2s1

Recorded check status: selected primary read with limits

ID / status: S012 B
Version/effect; actor, debt and jurisdiction limits: FCA G; display last updated 23 Oct 2025 (subrules have own dates). UK designated professional bodies and regulated incidental services. handbook.fca.org.uk
Direct source URLs: https://handbook.fca.org.uk/handbook/prof2/prof2s1

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R008", "scope": "Selected professional-exemption guidance only. Unread intervening and later conditions not certified complete; actual body-approved rules retained as hold.", "version_and_limits": "FCA explanatory guidance, not complete current FSMA326–332 body or exact approved schedule.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S013 Saved research record

FCA, PROF 2 Annex 1.1, designated bodies including Law Society of Northern Ireland and accountancy bodies. https://handbook.fca.org.uk/handbook/prof2/prof2s2?timeline=true

Recorded check status: selected primary read with limits

ID / status: S013 B
Version/effect; actor, debt and jurisdiction limits: FCA G annex updated 6 July 2006; historic designation list—current applicability also conditional upon statutory/body rule changes. Not the NI insolvency RPB roster. handbook.fca.org.uk
Direct source URLs: https://handbook.fca.org.uk/handbook/prof2/prof2s2?timeline=true

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R009", "scope": "Annex expressly lists LawSocietyNI as designated professional body, distinct from NI insolvencyRPB recognition. Historical designation list not a current licence/permissions roster.", "version_and_limits": "Annex lastupdated6July2006; dated designation history. Retrieval2026does not make every current professional rule newly verified.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S014 Saved research record

FCA, FEES 3 Annex 1, Part 2 activity groups CC1/CC2; Annex 1A pricing categories; FEES 3.2. https://handbook.fca.org.uk/handbook/fees3

Recorded check status: selected primary read with limits

ID / status: S014 B
Version/effect; actor, debt and jurisdiction limits: Binding R fee provisions; Annex 1A last updated 2 July 2026: category 3 £1,130, category 6 £11,260. Application fees only, subject to category/other rules; UK including NI. handbook.fca.org.uk +1
Direct source URLs: https://handbook.fca.org.uk/handbook/fees3

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R010", "scope": "Complete selected CC1limitedpermission/NFP nofee and CC2categories3/6 mapping, plus corresponding category prices. Other activity combinations/classifications and applicant eligibility held.", "version_and_limits": "Prices Annex1A effective2July2026; handbook broader lastupdate/future dates are separate. Applicationfee not customercharge or Part4Apermission definition.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S015 Saved research record

FCA, CONC 10.1.1–10.1.6, 10.2.1–10.2.14, prudential-resource application, £1m nonprofit test, formula, £5k minimum, professional exception. https://handbook.fca.org.uk/handbook/conc10

Recorded check status: selected primary read with limits

ID / status: S015 B
Version/effect; actor, debt and jurisdiction limits: Binding R versus marked G. Chapter shows last update 1 July 2014; current interface accessed 26 Oct 2026. Applicable UK debt-management firms including NI; not every debt adviser. handbook.fca.org.uk +1
Direct source URLs: https://handbook.fca.org.uk/handbook/conc10

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R011", "scope": "Complete selected10.1application/professional exclusion, solvency/ongoing resource rules, accounting-date base/tierformula/floor/newpermission projection and IPcapacity exclusion; greater15%recalculation and14daynotification. No full10.3capital eligibility or financial-accounting opinion. Incidental agency examples outside supplied report not recomputed/adopted.", "version_and_limits": "FCA bindingR and interpretiveG labels distinguished, rules variously2014. £1mclient-money application threshold not same as relevant-debt denominator; professional50%income rule permits temporary≤5%variation.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S016 Saved research record

UK Treasury, Payment Services Regulations 2017, regs.2, 4–5; Sch.1 Part 1 para.1(f), Part 2; Sch.3. PDF, P11–P14 printed approximately pp.12–15; P93–P96 printed pp.94–97 for capital/own funds. https://www.legislation.gov.uk/uksi/2017/752/pdfs/uksi_20170752_en.pdf

Recorded check status: not newly reopened original hold retained

ID / status: S016 B
Version/effect; actor, debt and jurisdiction limits: As-made 2017, later changes not comprehensively consolidated here. Payment institutions, stand-alone remittance and exclusions; UK including NI. Not an automatic classification for DMP transfers. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/uksi/2017/752/pdfs/uksi_20170752_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S017 Saved research record

FCA, PERG 15.2 Q9, Q11–Q11B, payment activity as a business in its own right, ordinary ancillary DMP examples and dual FSMA/payment capacities. https://handbook.fca.org.uk/handbook/perg15/perg15s2

Recorded check status: selected primary read with limits

ID / status: S017 B
Version/effect; actor, debt and jurisdiction limits: FCA G current accessed page; UK payment-service providers, including NI; fact-sensitive exception, not unconditional authorisation. PERG 15.2 General
Direct source URLs: https://handbook.fca.org.uk/handbook/perg15/perg15s2

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R012", "scope": "Selected payment-provider framework, completeQ9 ancillary-versus-independent activity explanation, selectedQ11–11B categories. Not current fullPSRs2017 or all thresholds/exclusions.", "version_and_limits": "FCA guidance as returned, underlying2017statutory amendments/authorisation/capital/safeguarding remain held.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S018 Saved research record

FCA, Apply to become an electronic money or payment institution, application/registration gateway. https://www.fca.org.uk/firms/apply-emoney-payment-institution

Recorded check status: not newly reopened original hold retained

ID / status: S018 B
Version/effect; actor, debt and jurisdiction limits: FCA official page current accessed 26 Oct; webpage last-updated marker 20 Aug 2026. Payment providers, not every debt firm; procedural costs/details outside narrow pass. FCA
Direct source URLs: https://www.fca.org.uk/firms/apply-emoney-payment-institution

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S019 Saved research record

FCA, Safeguarding requirements for EMIs and payment institutions, scope of payment-institution safeguards. https://www.fca.org.uk/firms/emi-payment-institutions-safeguarding-requirements

Recorded check status: not newly reopened original hold retained

ID / status: S019 B
Version/effect; actor, debt and jurisdiction limits: FCA official page current at access; includes 2026 material, but no full client-money/safeguarding audit undertaken. UK including NI when payment gateway actually applies. FCA
Direct source URLs: https://www.fca.org.uk/firms/emi-payment-institutions-safeguarding-requirements

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S020 Saved research record

UK legislation publisher, Insolvency (Northern Ireland) Order 1989, S.I.1989/2405 (N.I.19), attempted full contemporary revision and narrower arts. 3, 208U, 227–236, 348–350. https://www.legislation.gov.uk/nisi/1989/2405/2026-06-25/data.html

Recorded check status: not newly reopened original hold retained

ID / status: S020 F/I
Version/effect; actor, debt and jurisdiction limits: 26 Oct 2026 full-body fetch failed (timeout); separate article pages produced unsupported XHTML. Search-index extracts of 349 and 208U were viewed but not treated as body-read. Historical and subsequently amended text separately supported by S021–S032. This is an explicit current-consolidation gap. Internal Error +2
Direct source URLs: https://www.legislation.gov.uk/nisi/1989/2405/2026-06-25/data.html

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S021 Saved research record

NI Assembly, Insolvency (Amendment) Act (Northern Ireland) 2016, ss.14–17; Schedule 2 transition paras.11–16; Schedule 3 paras.4–15; Schedule 4 repeal of arts.348A/351–354. PDF P13–P17, printed pp.10–14; P40–P44, printed pp.37–41. https://www.legislation.gov.uk/nia/2016/2/pdfs/nia_20160002_en.pdf

Recorded check status: selected primary read with limits

ID / status: S021 B
Version/effect; actor, debt and jurisdiction limits: Enacted 29 Jan 2016; substantive provisions commenced separately, notably 2016 officeholder reform and repeal. NI only; authoritative amended statutory wording, not proof that every provision was effective at Royal Assent. legislation.gov.uk +1
Direct source URLs: https://www.legislation.gov.uk/nia/2016/2/pdfs/nia_20160002_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R013", "scope": "Enacted2016s14 inserts complete349A(1)–(3) and349B(1)–(10), including partnership-liability restrictions, later-awareness court/replacement routes and permitted period; selected repeal/savings schedules. No complete current1989Order/amendment/commencement chain or actual appointment.", "version_and_limits": "48-page parsedPDF, headermetadata Draft but document cover2016CHAPTER2. Selected PDF13–15/printed9–11 and schedule pages as returned; no pixels. Enacted historical text only.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S022 Saved research record

NI Assembly, Debt Relief Act (Northern Ireland) 2010, s.1 introducing 1989 Order Part VIIA; arts.208A–208E and 208U, especially intermediary and competent authority. PDF P1–P4 printed pp.1–4; P15–P17 printed pp.15–17. https://www.legislation.gov.uk/nia/2010/16/pdfs/nia_20100016_en.pdf

Recorded check status: selected primary read with limits

ID / status: S022 B
Version/effect; actor, debt and jurisdiction limits: As enacted 2010; commenced by separate instruments, not assumed immediately effective. NI DROs only. Later threshold/qualification amendments not audited in this narrow gateway. Front Cover of Act.doc +1
Direct source URLs: https://www.legislation.gov.uk/nia/2010/16/pdfs/nia_20100016_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R014", "scope": "Entire selected208U(1)–(10), individualintermediary/competentauthority/charging boundary and ORdefinition. Not full208C–E or current amendedDROregime.", "version_and_limits": "Enacted2010statute parsedPDF19–20 and definition vicinity; no current consolidated1989Order or2011licence-language reconciliation. No pixels.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S023 Saved research record

NI Department, Debt Relief Orders (Designation of Competent Authorities) Regulations (Northern Ireland) 2011, regs.2–10: designation, fit/proper body, restricted designation, individual intermediary approval, training/insurance/documents. PDF P0–P5, printed pp.1–6. https://www.legislation.gov.uk/nisr/2011/15/pdfs/nisr_20110015_en.pdf?wrap=true

Recorded check status: not newly reopened original hold retained

ID / status: S023 B
Version/effect; actor, debt and jurisdiction limits: As-made 2011. References to historic consumer-credit licensing require 2014/current-law reconciliation. NI DRO competent authorities and individual intermediaries. N4713_floating.doc +1
Direct source URLs: https://www.legislation.gov.uk/nisr/2011/15/pdfs/nisr_20110015_en.pdf?wrap=true

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S024 Saved research record

NI Department for the Economy, Debt Relief Orders, discussion of Official Receiver, approved advisers and agency role, especially page sections “What is a debt relief order?” and “More information.” https://www.economy-ni.gov.uk/topics/debt-relief-orders

Recorded check status: selected primary read with limits

ID / status: S024 B
Version/effect; actor, debt and jurisdiction limits: Live NI agency page accessed 26 Oct 2026; may include newer product eligibility thresholds not adopted in P01. NI public guidance, not a substitute for individual approval. Department for the Economy
Direct source URLs: https://www.economy-ni.gov.uk/topics/debt-relief-orders

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R015", "scope": "AgencyDRO role explanation. Returned fullconsumer thresholds/asset/income amounts and duration are outside this narrow review and not certified or used to build scenarios.", "version_and_limits": "Current official overview only, no exact personal eligibility or full statutory process.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S025 Saved research record

NI Department for the Economy, List of competent authorities in relation to the debt relief scheme, publication metadata and designated-organisation document link. https://www.economy-ni.gov.uk/publications/list-competent-authorities-relation-debt-relief-scheme

Recorded check status: selected primary read with limits

ID / status: S025 B
Version/effect; actor, debt and jurisdiction limits: Published 26 May 2015, last updated 22 Apr 2024. Page body-read, linked Word attachment not body-read. Thus names/completeness of the current list are not certified. Department for the Economy
Direct source URLs: https://www.economy-ni.gov.uk/publications/list-competent-authorities-relation-debt-relief-scheme

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R016", "scope": "Competent-authority list landingmetadata only. LinkedWordattachment/roster not opened.", "version_and_limits": "2015publication updated22April2024; not accepted as complete current list or actual designation.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S026 Saved research record

NI Department for the Economy, S.R.2025 No.170, Insolvency Practitioners (Recognised Professional Bodies) (Revocation of Recognition) (No.2) Order (NI), arts.1–2. PDF P0–P1, printed pp.1–2; explanatory P2, printed p.3. https://www.legislation.gov.uk/nisr/2025/170/pdfs/nisr_20250170_en.pdf

Recorded check status: selected primary read with limits

ID / status: S026 B
Version/effect; actor, debt and jurisdiction limits: Effective 5 Nov 2025; removes Law Society of NI from NI insolvency RPB schedule. Not an FSMA s.326 designation repeal. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/nisr/2025/170/pdfs/nisr_20250170_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R017", "scope": "Operative2025/170arts1–2 removeLawSocietyNIrecognition effective5November2025; explanatorynote separates background CAIrelandrevocation. No full current RPB roster.", "version_and_limits": "4-page parsedSRPDF operativepage0/printed1 and note page1. No pixels; separate FSMA designation not repealed by this instrument.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S027 Saved research record

NI Department for the Economy, Insolvency Service notice—revocation of recognition of the Institute of Chartered Accountants in Ireland as an RPB, paragraphs about art.350N and effective date. https://www.economy-ni.gov.uk/articles/insolvency-service-notice-revocation-recognition-institute-chartered-accountants-ireland-recognised-professional-body-economy-0

Recorded check status: selected primary read with limits

ID / status: S027 B
Version/effect; actor, debt and jurisdiction limits: NI Department notice: 19 Feb 2025 effective; describes move of authorisations. The corresponding S.R.2025 No.19 was not separately body-read, a narrower evidentiary limit. Department for the Economy
Direct source URLs: https://www.economy-ni.gov.uk/articles/insolvency-service-notice-revocation-recognition-institute-chartered-accountants-ireland-recognised-professional-body-economy-0

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R018", "scope": "Complete selected agencyrevocation notice, CAIreland effective19February2025 and reasons. No underlying2025/19body, no namedIP inquiry/list status.", "version_and_limits": "Notice11February2025, historicaladministrative evidence; exactunderlyingorderbody held.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S028 Saved research record

NI Department for the Economy, Insolvency Service notice—Law Society NI RPB recognition revocation, art.350N notice/reasons. https://www.economy-ni.gov.uk/publications/insolvency-service-notice-revocation-recognition-law-society-northern-ireland-recognised-professional-body

Recorded check status: not newly reopened original hold retained

ID / status: S028 B
Version/effect; actor, debt and jurisdiction limits: Dated 5 Nov 2025; confirms practitioner transition, distinct from FCA designated-professional status. NI specific. Department for the Economy
Direct source URLs: https://www.economy-ni.gov.uk/publications/insolvency-service-notice-revocation-recognition-law-society-northern-ireland-recognised-professional-body

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S029 Saved research record

NI Department, Insolvency Practitioners Regulations (Northern Ireland) 2006, especially regs.2, 6–10, 12 and Sch.2 paras.1–3. PDF P2–P5, printed pp.3–6; bond P11–P13, printed pp.12–14. https://www.legislation.gov.uk/nisr/2006/33/pdfs/nisr_20060033_en.pdf

Recorded check status: not newly reopened original hold retained

ID / status: S029 B
Version/effect; actor, debt and jurisdiction limits: As-made 2006, professional fitness/training and original £250k general-bond term; substantially amended after 2006, including S030. Historic officeholder qualification references cannot supersede 2016 reforms. N2491_floating.doc +1
Direct source URLs: https://www.legislation.gov.uk/nisr/2006/33/pdfs/nisr_20060033_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": null, "scope": "Originalsourcecell/access/versionholdretained;nonewsourcebodyread.", "version_and_limits": "Originalrecordremainsauthorityforhistoricalaccessclaimonly;notfreshverification.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S030 Saved research record

NI Department for the Economy, S.R.2025 No.177, Insolvency Practitioners (Amendment and Transitional Provisions) Regulations (NI) 2025, regs.1, 3–6, Sch.2 substituted bond terms. PDF P0–P3, printed pp.1–4. https://www.legislation.gov.uk/nisr/2025/177/pdfs/nisr_20250177_en.pdf

Recorded check status: selected primary read with limits

ID / status: S030 B
Version/effect; actor, debt and jurisdiction limits: Operative 9 Dec 2025 with pre-1 Jan 2027 bond/appointment saving. NI IP fraud/dishonesty security, £750k prospective general penalty sum, not consumer-money guarantee. legislation.gov.uk +1
Direct source URLs: https://www.legislation.gov.uk/nisr/2025/177/pdfs/nisr_20250177_en.pdf

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R019", "scope": "Selected commencement/£750kGPS change, securityloss/expiry provisions and complete6pre2027bond-and-appointment saving including subsequentcapacity. No fullamended2006regulations, allbondclauses or compensation entitlement.", "version_and_limits": "8-page PDF; selectedmaterialPDF0–3/printed1–4, not a4-pagewholePDF. Commencement9December2025 and pre2027saving distinct. No pixels.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S031 Saved research record

NI Assembly, Insolvency (Amendment) Act (NI) 2026, Part 8, s.93(1)–(6) repeal of fast-track voluntary arrangements and existing-case saving. https://www.legislation.gov.uk/nia/2026/6/part/8/data.html

Recorded check status: selected primary read with limits

ID / status: S031 B
Version/effect; actor, debt and jurisdiction limits: Royal Assent 24 June 2026 is distinct from substantive commencement. NI s.93 commenced 16 Oct 2026 by S032. No PDF pagination for this HTML section. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/nia/2026/6/part/8/data.html

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R020", "scope": "Entire selectedPart8s93 repeal plus6saving: specifieddocument AND statement suppliedbeforecommencement, not blanketpreservation of every oldcase.", "version_and_limits": "2026Act sectionbody, not wholeAct or full1989consolidation.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S032 Saved research record

NI Department for the Economy, S.R.2026 No.180, Insolvency (Amendment) (2026 Act) (Commencement No.1 and Transitional Provisions) Order (NI) 2026, arts.2(1)–(2)(n),(s), 3–5. https://www.legislation.gov.uk/nisr/2026/180/made/data.html

Recorded check status: selected primary read with limits

ID / status: S032 B
Version/effect; actor, debt and jurisdiction limits: Made 15 Oct, relevant provisions in force 16 Oct 2026; other provisions expressly future or commenced for preparatory/delegated purposes only. NI, no PDF pages for HTML. legislation.gov.uk
Direct source URLs: https://www.legislation.gov.uk/nisr/2026/180/made/data.html

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R021", "scope": "Selectedcommencementorder2(1)date16October2026 and2(2)(n)s93; surroundingprovisionsreturnedbut no whole740lineorder/currentcaseorallcommencements opinion.", "version_and_limits": "MadeSR2026/180 explicitcommencement, not publicationdate substitution.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S033 Saved research record

FCA, FCA Firm Checker, guidance for confirming permitted financial service identity. https://www.fca.org.uk/consumers/fca-firm-checker

Recorded check status: selected primary read with limits

ID / status: S033 B
Version/effect; actor, debt and jurisdiction limits: Public official guidance accessible 26 Oct 2026; consumer read-only lookup workflow described, not performed. UK including NI. FCA
Direct source URLs: https://www.fca.org.uk/consumers/fca-firm-checker

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R022", "scope": "Genericcheckerpurpose: authorisation/permission and risklimitations. No individual/entityquery or checkerresults.", "version_and_limits": "Current FCApubliclanding; underlyingservice/actualpersonnotused.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S034 Saved research record

FCA, Financial Services Register, listing types and status/permissions information. https://www.fca.org.uk/firms/financial-services-register

Recorded check status: selected primary read with limits

ID / status: S034 B
Version/effect; actor, debt and jurisdiction limits: Official register guidance accessed 26 Oct 2026. No person/firm record was queried. Registration and authorisation classes are not interchangeable. FCA
Direct source URLs: https://www.fca.org.uk/firms/financial-services-register

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R023", "scope": "Genericregisterpurpose, current/historicalrecords, unauthorised/clonewarnings and rolecheckinstructions. No namedquery, paidextract, APIkey/use or actualpermissioncertification.", "version_and_limits": "Page lastupdated13February2026; genericguidance only.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S035 Saved research record

NI Department for the Economy, Find an insolvency practitioner, official directory search description. https://www.economy-ni.gov.uk/services/find-insolvency-practitioner

Recorded check status: selected primary read with limits

ID / status: S035 B
Version/effect; actor, debt and jurisdiction limits: Live webpage accessed 26 Oct 2026; no search undertaken. Directory results may not by themselves establish officeholding in a particular case. Department for the Economy
Direct source URLs: https://www.economy-ni.gov.uk/services/find-insolvency-practitioner

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R024", "scope": "NI find-IP landing/directorypurpose only. Underlyingsearch/list notopened; no realIPquery or freshreplication of optional-list warning.", "version_and_limits": "Current agencylanding notexhaustiveauthorisationroster.", "whole_source_or_current_law_accepted": false}

C_NI-P01-S036 Saved research record

NI Department for the Economy, Statement of Insolvency Practice 3.1—Individual Voluntary Arrangements, introductory official description of IP as adviser/nominee/supervisor. https://www.economy-ni.gov.uk/publications/sip-31-individual-voluntary-arrangements

Recorded check status: selected primary read with limits

ID / status: S036 B
Version/effect; actor, debt and jurisdiction limits: Page published 1 July 2014; page body read, linked SIP PDF not read. This supports the NI IVA role distinction only; not a full 2026 procedures/conduct statement. Department for the Economy
Direct source URLs: https://www.economy-ni.gov.uk/publications/sip-31-individual-voluntary-arrangements

Recorded coordinator check boundaries

coordinator review: {"reviewed_at": "2026-10-29T04:55:30.036946+00:00", "reviewer": "delegated coordinator /root/review_wi1", "review_file": "[internal evidence reference]", "source_check_file": "[internal evidence reference]", "read_id": "C_NI1-R025", "scope": "NI SIP3.1 landingrolelist(adviser,nominee,supervisor), not full linkedPDF/currentSIPcomplianceconditions.", "version_and_limits": "Published1July2014; legacylandingdoesnotcertifycurrentgoverningIVAprocedure.", "whole_source_or_current_law_accepted": false}

What was examined—and what is still missing

The saved component-level coverage record keeps answered, partial, blank and unresolved branches distinct. A coverage label is not acceptance of a whole subject or jurisdiction.

Search this report’s coverage and gaps

coverage-1 Saved research record