Biba said it was alarmed by the small number of firms which had applied for FSA authorisation, and warned firms that time was running out for the early application discount.
Biba regulation and compliance consultant Branko Bjelobaba, said: "Something is not quite right.
"With the FSA having started accepting registrations from November 2003 and applications from 19 January 2004, the total number of registrations looks extremely low with secondary intermediaries running at only 1,000 firms."
Biba said recent figures from the FSA showed that there had been a total of 9,000 applications so far, with 4,200 coming from mortgage firms and 3,700 coming from primary insurance intermediaries.
Bjelobaba said the situation was alarming. He said the responsibility stood with primary and secondary intermediaries to ensure that their distribution chains will be able to function when regulation comes into force.
"Examine your distribution chains very carefully as you will not be able to work with firms if they are not authorised or have been appointed as representatives of yours.
"Time is drifting and there are only just over 3 months to the close of applications at a discounted rate and all applications should ideally be in by 13 July 2004."