QFA exemptions in the UK

Financial advisers are regulated in the UK by the Financial Conduct Authority. There used to be passporting arrangements under which somebody authorised in another EU country could practice in the UK without further authorisation (and vice versa) but these came to an end with Brexit. There are some transitional arrangements for people who were already doing this when the Brexit transition period ended, but they won't cover you.

So you'll need to get an authorisation in the UK, and will need to comply with whatever requirements they impose. The key question is what recognition they will afford to the diploma that you obtained in Ireland — Do they ignore it and require you to get a UK diploma? Do they accept it as equivalent to a UK diploma? Or do they accept it as largely equivalent to a UK diploma, but require you to complete some courses on UK-specific matters not covered by the Irish diploma? I'm afraid I don't know the answer to this question; there doesn't seem to be a section on the FCA website that discusses the situation of foreign advisers wishing to seek authorisation in the UK. I suggest you contact the FCA to see what they can tell you.

The other question that may be relevant is whether you intend to practice in the UK on your own account, or whether you are simply looking to be employed in the UK by a financial advice firm. If you're just looking for an employed position, working for an already-authorised UK firm, the requirements you face may be less onerous.

I would certainly try to register with the FCA asap, but you probably are too late as there was a cut-off date for many activities in March last. I think it also would depend on your QFA - is an actual qualification or are you ‘grandfathered’ as a QFA here? For business in the UK it has been ‘status quo ante’ for insurers and will be so until the end of this year, the usual passporting rules currently apply. However, nobody in the UK seems to have any idea of what is happening after year-end. (Yet another oven-ready deal!)

Maybe I'm too late in my response as I just saw this thread but here's my two cents. QFA is a threshold level qualification in Ireland for giving financial advice, although not all who hold the qualification give advice/are client facing. Under the previous regime the client facing role was Controlled Function 30 (CF30). There were various designations - similar to QFA - that were acceptable to the FCA to be approved for this role. Typically, Level 4 RDR under either CISI, IMC through CFAI UK or the CII exams if you are in the insurance industry.

Under the new Senior Managers Certification Regime (SMCR) the "Client Dealing" function is no longer approved by the FCA, but by the firm. This means that it is incumbent upon the firm - not the regulator - to designate the appropriate qualification. So, one firm may use the CISI framework (the majority do in my experience) and another may use CFAI UK etc.

So, you need to find out which firm you will work for. Then, you need to see which framework they use; CISI/CFAI/CII. Then, you need to see what - if any - exemptions you will get from the framework provider by virtue of your existing qualification. You will almost certainly need to sit the regulatory module (IMC1 if CFAI) no matter which one you work with. If you are going to apply for jobs on spec, start by asking CISI what it takes to be RDR Level 4 or CII if you're in the insurance as opposed to investment industry.

Best of luck in the City!