UK AR Technology Checklist
Operational technology requirements for Appointed Representatives launching under a regulatory host.
Launching as an Appointed Representative under a regulatory host (Brooklands, Carne, Portman Square) gives you market access while you build track record. But regulatory hosts increasingly require evidence of genuine operational infrastructure — not just a mailbox arrangement. This checklist covers what you need.
Step-by-Step Checklist
1. Demonstrate Operational Substance
Regulatory hosts scrutinise AR operations more closely since FCA's review of the AR regime. Your technology infrastructure demonstrates genuine business substance — not reliance on your host's systems for everything.
Can you demonstrate independent operational capability to your regulatory host?
2. Critical Third Party Regime Awareness
Since November 2024, the FCA and Bank of England can directly oversee cloud providers deemed Critical Third Parties. While this primarily targets the largest providers, it creates reputational risk for funds using CTP-designated infrastructure. Self-hosted technology eliminates CTP designation risk entirely.
Is your cloud infrastructure provider at risk of CTP designation?
3. Deal Analysis Infrastructure
Institutional LPs evaluate your operational maturity. An AR using Excel for deal analysis signals a team that is not ready for institutional capital. Deploy a proper deal analysis platform with audit trails and adversarial verification.
Would an LP operational due diligence team be satisfied with your deal analysis process?
4. UK GDPR & Data Protection
Ensure your technology stack is UK GDPR compliant. Data processing agreements with all technology vendors. Document your data flows and retention policies. The ICO is active in enforcement.
Have you completed a data protection impact assessment for your fund operations?
5. Operational Resilience
FCA requires identification of important business services and setting of impact tolerances. Document your technology dependencies, single points of failure, and recovery procedures.
If your primary systems went down, how long before your fund operations resume?
Frequently Asked Questions
What technology does a UK AR need?
Deal analysis platform, document management, secure communications, and compliance infrastructure. Self-hosted options avoid Critical Third Party regime risk and demonstrate operational substance to your regulatory host.
How does the CTP regime affect fund technology choices?
The Critical Third Parties regime (Nov 2024) gives the FCA and Bank of England oversight over systemically important cloud providers. Self-hosted infrastructure like DiligenceWorks is not subject to CTP designation because no third-party cloud provider is involved.
Ready to See DiligenceWorks in Action?
DiligenceWorks provides self-hosted infrastructure that eliminates CTP risk and demonstrates operational substance. Book a discovery call.
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