4.3 Display of Licences & Authorisation Visibility

4.3 Display of Licences & Authorisation Visibility

Quick Answer: Under FAIS section 8(8), a licensee must (a) display a certified copy of the licence in a prominent and durable manner at every business premises, (b) ensure reference to the licence appears in business documentation, advertisements and promotional material, and (c) ensure the licence is available immediately or within a reasonable time for production to any person requesting proof of licensed status under law or for entering a business relationship. Section 8(9) forbids using a licence for business purposes when it has lapsed or been withdrawn, or during provisional or final suspension. Representatives must make authorisation visible in practice when they meet clients.

Why visibility is a Task 2 topic

Licensing only protects the public if clients and counterparties can see and verify who is authorised. A licence locked in a head-office safe, while representatives sell from unmarked offices under personal brands, defeats the purpose of section 8. Display and related visibility duties turn the private fact of authorisation into a public accountability tool.

For RE5 candidates, this section closes QC coverage on contributing to licence maintenance: you are not expected to hang frames as a facilities manager, but you are expected to know what the Act requires, why it matters, and how your client-facing behaviour supports or undermines it.

Section 8(8) unpacked

(a) Premises display

The licensee must display a certified copy of the licence:

Exam trap: “We display it at head office only” is generally insufficient if the firm operates multiple business premises.

(b) Documentation, advertisements and promotional material

The licensee must ensure that a reference to the fact that a licence is held is contained in:

• business documentation;
• advertisements; and
• other promotional material.

In practice this is why letterheads, email footers, proposal packs, websites, and adverts carry wording such as the FSP name and FSP licence number. Representatives who create their own flyers or WhatsApp broadcast graphics without those references can place the firm in breach even if the head-office template is compliant.

(c) Production on request

The licence must be available immediately or within a reasonable time for production to any person requesting proof of licensed status:

• under authority of a law; or
• for the purpose of entering into a business relationship with the licensee.

This supports regulators, product suppliers, counterparties, and serious clients who verify authorisation before engaging. A representative’s correct response when a client asks “Are you licensed?” is not defensiveness — it is to facilitate verification (FSP name, FSP number, FSCA register checks, and production of licence proof through firm channels).

Section 8(9): do not trade on a dead or suspended licence

Section 8(9) provides that a person may not in any manner make use of any licence or copy thereof for business purposes where:

• the licence has lapsed; or
• the licence has been withdrawn; or
• subject to the suspension provisions, during any time when the licensee is under provisional or final suspension under section 9.

This pairs with section 4.1: during suspension the provider is treated as unauthorised. Keeping a framed licence on the wall and still writing new business as if authorised is exactly the mischief section 8(9) targets. If a licence is suspended, marketing and premises displays must not mislead clients into believing ordinary authorised business continues.

Scenario: suspended firm, active brochure

An FSP is provisionally suspended. A representative continues handing out brochures that say “Licensed FSP — fully authorised to advise” and points to an old certified copy on the wall. That conduct risks breaching section 8(9) and misleads clients. Correct conduct follows the firm’s suspension terms: stop new business as required, communicate status truthfully, and stop using the licence as if it were in good standing.

Implications for representatives meeting clients

Representatives are the human face of authorisation visibility. Even when the premises copy is perfectly framed, client meetings — especially off-site — need disciplined practice.

What “good” looks like in a client meeting

1. Identify the FSP by legal/business name used in licensing.
2. State the FSP licence number (and be ready to show how the client can verify on the FSCA register).
3. State your capacity — representative of that FSP (not a personally licensed FSP unless that is actually true).
4. Disclose supervision if you render services under supervision.
5. Use approved materials that already contain licence references.
6. Stay inside appointment scope so the visible licence is not a backdrop for unauthorised services.
7. If meeting at firm premises, ensure you are not covering or removing the displayed certified copy for “a cleaner look” during open days or photoshoots.

Off-site and digital meetings

Many financial services are rendered in clients’ homes, workplaces, or video calls. Section 8(8)(a) still binds the premises of the licensee; it does not vanish because you also do field work. For field and digital channels, subsections (b) and (c) and GCOC disclosure duties carry much of the visibility load:

• Virtual backgrounds and personal LinkedIn pages are not an excuse to hide the FSP.
• PDF proposals and e-application packs are business documentation — they need licence references.
• If a client requests proof of licensed status before signing, escalate promptly so the firm can produce it within a reasonable time.

Scenario: rep rendering services outside authorised subcategory (visibility angle)

Facts: A firm’s wall displays a certified Category I licence. The licence and the representative’s appointment cover long-term insurance, not forex investment products. The representative meets a client under that impressive wall display and recommends a forex investment product “because we are a licensed FSP.”

Analysis:

• Display proves some authorisation exists; it does not prove every product is authorised.
• Using the displayed licence as a halo for out-of-scope services is misleading and combines section 13 scope failure with poor transparency.
• Correct conduct: explain the actual authorised categories, decline forex if not authorised/appointed, and refer appropriately.

Scenario: failing to disclose FSP name and licence number (visibility angle)

Facts: A representative meets a client at a restaurant, uses only a personal notebook, and verbally discusses “my products.” No FSP name, no FSP number, no brochure with licence reference. The client later cannot find the firm on the FSCA register because they only remember the representative’s nickname.

Analysis:

• The client has lost the accountability trail FAIS requires.
• Even if the firm’s office display is perfect, this interaction failed authorisation visibility.
• Complaints, premium disputes, and replacement disputes become harder to allocate — a regulatory red flag for the licensed provider’s control environment.

Repair behaviours: standardised opening disclosure scripts; branded packs with FSP number; follow-up emails from a firm domain with licence footer; recording the FSP identity on the needs-analysis and record-of-advice documents.

How display duties connect to other FAIS pillars

Common non-compliance patterns (exam radar)

1. No display at branches — only head office compliant.
2. Uncertified or outdated copy — old licence after category changes; amended licence not replaced on the wall.
3. Marketing without licence reference — rogue rep adverts and informal flyers.
4. Personal branding that erases the FSP — “independent” positioning without licensed-provider identity.
5. Using suspended/lapsed licence imagery — website badge left live after suspension.
6. Wall licence used to sell out-of-scope products — authority visibility without scope honesty.

Practical firm-and-rep checklist

For the FSP / premises managers

• Certified copy displayed prominently at each business premises.
• Process to replace displays when the licence is amended.
• Template control so all client-facing docs and ads include licence reference.
• Protocol for producing the licence quickly on request.
• Immediate scrub of public licence claims if suspended, withdrawn, or lapsed.

For the representative

• Always name FSP + licence number in first substantive contact.
• Use only approved promotional material.
• Never imply personal FSP licensing if you are a representative only.
• Disclose supervision status where applicable.
• Do not point to a wall certificate to justify a product outside appointment.
• If a client asks for proof, facilitate firm production — do not invent documents.

Integrating the three Chapter 4 sections

If you can explain, in one breath, that authorisation is granted under section 8, maintained through fit and proper and lawful conduct, demonstrated through display and disclosure, and endangered by out-of-scope or dishonest services, you are ready for Task 2 QC1–3 items before Chapter 5 expands enforcement detail.

Final exam tips

• Memorise the three limbs of section 8(8): premises display; docs/ads/promos; production on request.
• Link section 8(9) to suspension, withdrawal, and lapse — no business use of the licence artefact.
• In scenarios, prefer answers that increase client ability to verify the FSP.
• Distinguish display of a licence from scope of a licence — both must be right.
• Expect combined scenarios: non-disclosure of FSP number plus out-of-subcategory advice in a single stem.