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Whilst some press headlines have focused on the FCA cutting fees, it is important to consider the key components to understand the bigger picture...

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FCA fees and levies 2025/26 – what’s the impact on our sector?

Whilst some press headlines have focused on the FCA cutting fees, it is important to consider the key components and understand the bigger picture.

The FCA recently released its 2025/26 fees and levies consultation.

Whilst some press headlines have focused on the FCA cutting fees, it is important to consider the key components to understand the bigger picture.

The FCA allocates its annual funding requirement across different fee classes. Across the two fee classes relevant to the mortgage intermediary sector (A.18 and A.19), the FCA is looking to increase the overall amount it collects from firms.

However, due to a significant increase in financial penalty rebates (retained penalties received by the FCA in a financial year) it appears the funding requirement for our sector will be less than last year (2024/25).

This may seem positive; however, it doesn’t mean all mortgage intermediary firms will see reduced 2025/26 fee invoices.

Firstly, the FCA is looking to increase the minimum fee (paid by all firms) from £1,750 to £2,000.

Secondly, whilst firms will pay slightly less than last year on protection and GI business as the fee rate for this class has reduced, it appears the fee rate for mortgage business per £1,000 income (above £100,000) has increased. AMI believes this is because the number of firms in this fee class has reduced and income has remained static.

Where firms have Appointed Representatives (ARs), the FCA is moving towards a variable fee rate of £303.46 per AR (there is a reduced fee for IARs – we believe this will be 30% of the AR charge). This represents an increase on last year (2024/25: £289 per AR). The FCA has said that moving to a variable fee means it can recover the costs it needs rather than relying on AR/IAR numbers, which can be unpredictable.

What will my firm’s fee invoice look like for 2025/26?

The exact impact on a firm’s fees invoice will depend on factors such as the turnover of the business (in particular if the business has seen increased mortgage turnover) and the split between mortgage and protection business. AMI suggests firms use the FCA’s calculator, which has been updated for 2025/26, to estimate their fees invoice for this year. This will be updated with finalised fee rates once the FCA publishes its Policy Statement in July.

Please note it appears that when selecting ‘CC02 – consumer credit full permission’ in the calculator, the full consumer credit fee applies. Whilst the CC02 line will appear on firms’ invoices, there shouldn’t be a fee attached as most pay no fees because their consumer credit income is zero or falls below the minimum fee threshold.

We will raise this with the FCA and in the meantime, we suggest that when using the calculator firms do not tick the separate ‘CC02’ line. This will provide a more accurate comparison against 2024/25 fees.

Most firms will start to receive invoices from July (unless you are a larger firm, where you may have already been invoiced for an interim payment with the remaining balance invoiced in September).

AMI will be asking a selection of members to share (confidentially) their fee invoices, to better understand the impact on mortgage intermediary firms.

Our view

We are concerned about the continued upwards trajectory of FCA fees, particularly as the mortgage intermediary market is functioning well with low levels of customer complaints and inertia.

There is a lack of transparency from the FCA on:

  • How the £23m raised directly from our sector will be spent.
  • How it will utilise a £40m underspend from 2024/25*.
  • Its decision to proceed with a variable AR fee.

In addition, the FCA is asking for more money to fund its AR regime work – an additional £7.4m (paid by principals with ARs across numerous sectors), again in our view without supportive evidence on mortgage intermediary related harms. We also feel as the FCA has collected at least two years of data, what has been the outcome of any review of this data and should this not lead them to a more targeted approach. We are yet to see the benefits of a data led regulator translate through to cost savings.

In addition, there appears to be a lack of synergy between the FCA’s strategy and the cost to regulate – the FCA has recently announced a more streamlined remit and wants to be a smarter regulator, yet its cost base is increasing. We are keen to understand the FCA’s thoughts on this.

*This is mentioned in FCA board minutes yet is not included in the fees and levies consultation.

How is AMI supporting member firms?

We recognise the impact on firms of rising FCA fees, particularly against a backdrop of increasing business costs and for some a decrease in mortgage case income.

We are identifying key areas to draw to the FCA’s attention and to focus our lobbying efforts. Where relevant, we will lean on AMI members for insight and support.

AMI will ensure views of member firms are reflected in our FCA fees and levies consultation response. The AMI board help shape this response, however we also obtain insight through our industry groups and member breakfast meetings. Should you wish to feed into our response, please contact info@a-m-i.org.uk by Thursday the 8th of May.

Once submitted, our final response will be available to view on our website.

We will continue to keep members updated on developments.

© 2025 Association of Mortgage Intermediaries Limited.

AMI is the trading name of The Association of Mortgage Intermediaries Limited which is a company limited by guarantee, registered in England and Wales under the Companies Acts with number 7982341. Our registered address is Celixir House, Stratford Business & Technology Park, Innovation Way, Banbury Road, Stratford-upon-Avon, Warwickshire, CV37 7GZ.

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