Signposting StepEx finance: a guide for education providers and their staff
For admissions, marketing, student services and finance staff at education providers that offer StepEx finance, and for the compliance teams of institutions considering it. Part 1 is for front-line staff. Part 2 explains why the model does not require the provider to hold FCA permission.
PART 1: FOR YOUR STAFF
Why this matters
StepEx Lender Ltd is the lender. It is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 824928) and does everything that needs that authorisation: it creates and approves every promotion, assesses every applicant, makes every lending decision and manages every agreement. StepEx has designed the way providers work with it so that a provider does not need its own FCA permission. That depends on staff doing only two things: displaying StepEx's approved promotions and directing students to StepEx. If staff go further, for example by explaining the finance, helping with an application or passing a student's details to StepEx, the institution could be carrying on credit broking without permission, and anything staff say about the finance can be treated in law as said on StepEx's behalf.
The answer to any finance question
"StepEx offers finance for this course. Everything about it is on our StepEx page, and StepEx can answer any questions." Then give the student the link to your institution's StepEx page. Every participating provider has one; they are listed at stepex.co/finance-availability. That is the whole of your role.
Do
- Use only the promotions StepEx has created and approved for your institution, exactly as supplied: on fees and funding pages, course pages, prospectuses and enrolment emails.
- Link only to your institution's StepEx page.
- Give every student who asks about finance the same answer (above) and the link.
- Where your institution has Managed Promotions, point students to Request a call or Book a call on your StepEx page, so StepEx's finance expert can help them. Otherwise point them to the contact form at stepex.co/contact.
- Give out the referral code for a course when a student asks for it. Codes identify the course and the fee; a group paying a different fee, such as alumni, has its own code. A code is never for one student.
- Confirm a student's place, course and fee when StepEx asks you to, within 14 days.
- Send StepEx any new wording you want to use (including a social-media post, an email line or event material) and wait for approval before using it.
- Tell your StepEx account contact before using promotions in a new channel or at an external event.
- Tell StepEx straight away if a member of staff has said something about the finance that they should not have.
Don't
- Don't change, shorten or rewrite StepEx's promotions, or write your own finance messages.
- Don't describe the finance in your own words: no monthly amounts, interest, APR, fees, terms or comparisons. Never say "interest free", "guaranteed", "instant" or "easy".
- Don't recommend or discourage borrowing, or say whether a student is likely to be approved.
- Don't help with any part of the application: forms, documents, Open Banking, identity checks or income questions.
- Don't pass a student's name, contact details or circumstances to StepEx. The student makes the contact.
- Don't collect students' details for finance, or build your own form or list for it.
- Don't link to, embed or pre-fill the StepEx application.
- Don't accept any payment, commission or other benefit from StepEx or a student for introducing students to StepEx.
- Don't collect or chase repayments, or discuss a student's StepEx account.
- Don't withhold certificates, results, graduation or course access because a student is behind with StepEx. The debt is StepEx's to collect.
What to say when a student asks
| What a student asks | What to say |
|---|---|
| "Can I pay for the course in instalments?" | "Yes, StepEx offers finance for this course. The details are on our StepEx page, and StepEx can answer any questions about it." Then give the link to your institution's StepEx page. |
| "How much would I pay each month?" / "Is it interest free?" / "What's the APR?" | "Everything about the cost is on our StepEx page, with an example for each option. StepEx can talk you through it." Do not quote, estimate or compare any figure, and never say "interest free". |
| "Will I be approved?" / "Is it worth applying?" | "StepEx makes that decision after its checks, so I can't say. The page explains who can apply." Do not predict an outcome, or encourage or discourage an application. |
| "Should I take the finance or pay upfront?" | "That's your decision and I can't advise on it. MoneyHelper gives free, impartial guidance on borrowing: moneyhelper.org.uk." |
| "Can you help me fill in the application?" | "I can't help with the application itself. StepEx can." Where your institution has Managed Promotions: "Use Request a call or Book a call on our StepEx page." Otherwise: "Use the contact form at stepex.co/contact." |
| "Can you call StepEx for me?" / "Can you put me through?" | Where your institution has Managed Promotions: "The quickest way is to book a call or request a callback on our StepEx page, and StepEx will call you." Otherwise: "Use the contact form at stepex.co/contact and StepEx will reply." |
| "What's the referral code?" | "The referral code for this course is…" (give the code) "…enter it when you apply to StepEx." |
| "I've applied. What's happening with it?" | "StepEx manages the application. Use the link in your StepEx emails, or the contact form at stepex.co/contact." |
| "I'm struggling with my repayments." | "Please tell StepEx straight away. There is help at stepex.co/support/money-worries, including free debt advice." Do not discuss the account or agree anything. |
| "I want to cancel the finance." | "Contact StepEx through stepex.co/contact. Cancelling the finance doesn't change your place on the course; that's a separate matter with us." |
| "I want to leave or defer the course." | Handle it under your own withdrawal, deferral and refund policy. Tell the student that if they have StepEx finance they should also tell StepEx. |
| A complaint about the finance | "Please use the contact form at stepex.co/contact and choose Complaint; StepEx will investigate." |
| A complaint about the course | Handle it under your own complaints procedure. If it could affect the student's finance (for example a refund, or a course that did not run as described), tell your StepEx account contact. |
Two things that are yours, not StepEx's
- The course. Admissions, the place, deferral, withdrawal, refunds and course complaints follow your own policies. A student who withdraws from the finance keeps their place unless they also withdraw from the course.
- Refunds of financed fees. If you agree to refund fees on a course a student financed through StepEx, the refund is paid to StepEx to reduce what the student owes, as your services agreement sets out. Tell your StepEx account contact.
Contacts
- Students: your institution's StepEx page; stepex.co/contact; where your institution has Managed Promotions, Request a call or Book a call on your StepEx page.
- Your staff: your StepEx account contact, for approvals, new channels, events, confirmations and anything that has gone wrong.
PART 2: WHY THE MODEL DOES NOT REQUIRE THE PROVIDER TO HOLD FCA PERMISSION
This part is StepEx's analysis of its own model. It is not legal advice to any institution. A provider's position depends on what it actually does; an institution that wants its own view should take advice from its own advisers, and StepEx will discuss the model with them.
Last reviewed 20 October 2026. Credit broking is a regulated activity. Article 36A of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 defines it as six activities carried on by way of business: introducing a person who wishes to enter a credit agreement to a lender; the same for consumer hire; introducing to another broker; presenting or offering an agreement that would be a regulated credit agreement; assisting a person with preparatory work towards such an agreement; and entering into such an agreement on behalf of a lender. Article 36C excludes the last three where the person receives no fee of any kind for the activity. Separately, section 21 of the Financial Services and Markets Act 2000 restricts the communication of financial promotions, but not where the content has been approved by an authorised person. The model keeps a provider outside each of these, not by relying on an exemption that turns on the provider's circumstances, but by removing from the provider every act the definition catches:
| Activity | Why it is not engaged |
|---|---|
| Introducing a student to the lender (article 36A(1)(a)) | You publish promotions StepEx has approved; you do not pass any student, or any student's details, to StepEx. An introduction brings two parties into contact; a published promotion is a one-way communication and StepEx learns of the student only when the student applies. Communicating an approved promotion is permitted to unauthorised persons by FSMA section 21(2)(b). |
| Introducing to another broker (36A(1)(c)) | There is none. StepEx Lender Ltd is the lender. |
| Presenting or offering an agreement (36A(1)(d)) | Excluded by article 36C where no fee is received for it. You receive nothing for displaying promotions; you pay StepEx's fees. What you receive is your course fee, paid to you as the student repays: your services agreement characterises it as deferred payment of the course price, with anything above the fee being compensation for the delay, and nothing paid by reference to introducing students or presenting finance. Payment upfront remains your preferred route: because finance receipts are deferred, are net of StepEx's fees and can be lost if a student defaults, the receipts from a financed student are worth less to you than the same fee paid upfront. Where you want this settled on any reading, the finance for your courses can be configured so that StepEx's fees are at least the charge for credit, so you never receive more than the course fee. |
| Assisting with the application (36A(1)(e)) | Your staff do not help with applications; StepEx's own staff do, under StepEx's permission. Article 36C would in any event exclude unpaid help. |
| Entering into the agreement for the lender (36A(1)(f)) | Never. The agreement is signed between the student and StepEx Lender Ltd on StepEx's systems. |
| Financial promotions (FSMA section 21) | Every promotion you use is created and approved by StepEx Lender Ltd, which is responsible for it under CONC 3. StepEx approves its own promotions, so it needs no separate approver permission under the 2024 financial promotions gateway. Approval covers fixed content only: it cannot cover what staff say in conversation, which is why the staff rules above exist. |
| Collecting repayments, administering agreements, debt advice (articles 39E to 39G) | You never collect or chase repayments, never administer the agreement, and refer students in difficulty to StepEx and to free debt advice. |
Sources: Financial Services and Markets Act 2000, sections 19, 21 and 22; Financial Services and Markets Act 2000 (Regulated Activities) Order 2001, articles 36A, 36C and 39E to 39G; FCA Perimeter Guidance Manual (PERG) 2.3, 2.7 and 8.22; FCA, Consumer credit: understanding permissions; FCA Policy Statement PS23/13 (financial promotions gateway); FCA Consumer Credit sourcebook (CONC) 3. StepEx Lender Ltd is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 824928). Step Exchange Ltd is the group holding company.