FCA financial promotions: a guide to compliant financial services advertising

Financial services advertising in the UK comes with a simple-sounding rule. Your financial promotions must be fair, clear and not misleading. The problem is that those seven words cover the claim itself, how prominently risks are presented, who receives the promotion, whether the audience is likely to understand it, the landing page, comparisons, representative rates, affiliates, influencers, and whether the person communicating the promotion was legally allowed to do so in the first place.

The FCA is actively enforcing all of it. Almost 20,000 financial promotions were withdrawn or amended following FCA intervention during 2024 alone, close to twice the number in 2023, and the regulator has continued stepping up enforcement since, including action against misleading social media advertising and unauthorised finfluencers.

This article covers what financial services advertisers actually need to settle before putting an advert live. If your immediate problem is Meta rejecting the ads rather than the underlying compliance position, the guide to financial services advertising on Meta deals with the platform side.

What actually counts as a financial promotion

A financial promotion is broadly an invitation or inducement to engage in certain financial activities, communicated in the course of business. That definition is considerably wider than a traditional advert. It can include:

• Facebook and Instagram ads
• Google Ads and LinkedIn ads
• TikTok videos and organic social posts
• Website pages and landing pages
• Emails and SMS messages
• Brochures and banner advertising
• Influencer posts and affiliate content

The FCA regulates advertising across loans, investments, bank accounts, insurance, pensions, mortgages, life assurance, payment services, claims management and qualifying cryptoassets. The rules are deliberately technology-neutral, so there is not one standard for a newspaper advert and a more relaxed one because you only had 15 seconds on Instagram.

Who is legally allowed to communicate one

Before worrying about whether the advert is well written, there is a more fundamental question: is the person communicating it entitled to do so?

Section 21 of the Financial Services and Markets Act creates what is usually called the financial promotion restriction. Broadly, an invitation or inducement to engage in relevant financial activity cannot be communicated unless the person communicating it is appropriately authorised, an authorised person lawfully approves the promotion, or an exemption applies.

That matters particularly for lead generation companies, affiliates, influencers, introducers, comparison websites, financial education businesses, marketing companies and unauthorised companies working alongside regulated firms.

Do not assume that having an FCA-authorised company somewhere in the commercial relationship makes every promotion in that chain legal.

Being authorised is not blanket approval

FCA authorisation relates to the activities your firm has permission to undertake. It is not sign-off for every advertisement your marketing department produces. The promotion still needs to comply with the Financial Services and Markets Act, the FCA Handbook, the rules applying to that particular product, Consumer Duty requirements where applicable, FCA guidance on financial promotions, and any other advertising or consumer protection legislation.

Different products sit in different parts of the Handbook. Consumer credit advertising falls heavily under CONC. Mortgage advertising falls under MCOB. Investment promotions can fall under COBS. Claims management advertising has rules within CMCOB. There is no universal disclaimer that makes every financial advert compliant.

Authorised firms cannot approve promotions for anyone they like

The approval regime changed significantly in 2024. Since 7 February 2024, authorised firms generally need specific approver permission from the FCA if they want to approve financial promotions for unauthorised persons outside relevant exemptions. There are exceptions, but existing authorisation does not automatically allow a firm to sign off another business's advertising.

This is an area of active scrutiny. In May 2026 the FCA published findings from a review of financial promotion approvers and criticised firms that approved adverts containing unsupported claims or allowed retail customers to see promotions intended for professional clients.

If your business relies on another regulated firm approving your promotions, establish whether that firm actually holds permission to approve them. "They are FCA authorised" is not the same answer.

The core rule: fair, clear and not misleading

This is more demanding than making sure everything in the advert is technically true. For consumer credit, FCA rules explicitly say promotions should be accurate, balanced and understandable, and should not disguise, omit or diminish important information or warnings. Benefits should not be emphasised without a fair and prominent indication of relevant risks.

Take an advert saying "reduce your monthly repayments by £400". That could be entirely true. But what if achieving it involves:

• Extending the borrowing period
• Securing unsecured debt against the customer's home
• Paying more interest overall
• Paying arrangement fees
• Refinancing an existing mortgage
• Meeting specific eligibility criteria

The headline does not become fair merely because all of that appears three screens down the landing page.

Technically true can still be misleading

Imagine 10% of applicants qualify for a lender's lowest rate. You could probably find a customer who received it. That does not mean the campaign should be built around "loans from 3.9%". Similarly, "borrow up to £100,000" might be correct, but if most of the target audience could never realistically borrow £100,000, the way that claim is presented deserves careful thought.

The FCA looks at the overall impression a promotion gives consumers. Compliance is not a game of finding wording that survives a technicality.

The useful question is not "is this defensible?" but "what will the average person reasonably take away from this advert?"

The Consumer Duty raises the bar again

For firms subject to the Consumer Duty, meeting the historic fair, clear and not misleading test is not necessarily the end of it. The FCA says firms should support retail customers by giving them the information they need, when they need it, in a form they are likely to understand. The consumer understanding outcome applies across communications before, during and after a sale, including advertising on social media.

That changes the question. Do not ask only whether you have disclosed something. Ask whether the intended customer will actually understand it. Those two questions produce very different advertisements. A 14-line disclaimer written by a compliance department might technically contain the important information without a single consumer taking any of it in.

The rules apply to Facebook, Instagram, TikTok and LinkedIn

The FCA's current social media guidance is FG24/1, published in March 2024. It makes clear that the financial promotion rules apply regardless of channel. Promotions on social should be fair, clear and not misleading, support consumer understanding, give a balanced view of benefits and risks, carry appropriate risk warnings, and help consumers make informed decisions.

A short-form platform is not an exemption. If Instagram Reels gives you no room to communicate the product fairly, that may mean the product, or that particular promotion, is not suitable for the format.

Every advert has to work on its own

One of the most useful principles in FG24/1 is standalone compliance. Each communication is considered individually. You generally cannot publish an incomplete financial promotion and assume the click through fixes it. The FCA has explicitly rejected the idea that a click-through approach universally solves character limits on social platforms.

So an advert reading "consolidate your debts and cut your monthly repayments", with the landing page carrying "your total borrowing costs could increase, your home may be repossessed", has a problem. The initial promotion itself needs to contain what is required to make that particular message fair and appropriately balanced.

The landing page does not rescue the advert. The advert is the promotion the consumer actually received.

Benefits and risks need balancing

Financial advertisers naturally want to advertise benefits. That is what advertising does, and there is nothing inherently wrong with telling customers they could lower monthly payments, release equity, access finance quickly, consolidate borrowing, earn returns, reduce fees or obtain compensation.

The problem arrives when the benefit takes centre stage while the material downside is hidden. A headline offering to unlock the money tied up in your home, with the repossession warning in tiny text underneath, technically contains the warning. The overall presentation may still be unbalanced. The FCA's consumer credit rules explicitly require risks to be indicated fairly and prominently rather than obscured or diminished.

Risk warnings have to be noticeable

Risk information should not merely exist. People need a realistic chance of noticing and understanding it. FG24/1 specifically addresses prominence and warns firms about risk information being obscured, truncated or poorly presented in digital formats. That means thinking about:

• Font size, contrast and placement
• How long it stays on screen in video
• Whether Instagram crops it
• Whether "see more" hides it
• Whether it appears only at the end of a video
• Whether another graphic dominates attention
• Whether carousel users have to swipe several times to reach it

Putting the risk information on slide five while slide one carries the sales claim is not something I would regard as safe.

A risk warning is not a compliance shield

Marketers sometimes treat regulatory warnings like a legal spell. Add the repossession wording and the rest of the advert can supposedly say anything. It cannot. A risk warning addresses one particular requirement. It does not fix misleading claims, unrealistic savings, false urgency, unfair comparisons, incorrect APR information, undisclosed fees, false endorsements, missing eligibility criteria, misrepresentation of the advertiser or poorly explained consequences.

Mortgage and secured loan adverts have prescribed wording

Where relevant consumer credit rules apply and borrowing may be secured on the customer's home, the Handbook can require the prescribed warning:

YOUR HOME MAY BE REPOSSESSED IF YOU DO NOT KEEP UP REPAYMENTS ON A MORTGAGE OR ANY OTHER DEBT SECURED ON IT.

Where the promotion says credit can be used to pay debts owed to other lenders, another prescribed statement can be required before that warning:

THINK CAREFULLY BEFORE SECURING OTHER DEBTS AGAINST YOUR HOME.

This is also why I would be cautious about copying competitors' secured loan ads. You do not know whether their compliance team approved them, which rules apply to their particular product, whether Meta simply happened to approve something non-compliant, or whether the advert is currently being investigated. Everyone else does it is weak protection in regulated advertising.

Consumer credit advertising has its own APR rules

Consumer credit deserves an article of its own. Current CONC 3 rules can require a representative APR in certain circumstances. Triggers include promotions implying credit is available to people whose access might otherwise be restricted, favourable comparisons, and incentives to apply.

The FCA gives language such as "poor credit accepted" or "all circumstances considered" as potentially triggering representative APR requirements. Phrases such as "cheapest", "best rates" or "competitive terms" can trigger requirements where they amount to favourable comparisons.

This is precisely why a marketing team should not generate a dozen bad credit loan headlines and publish them without compliance review. One apparently innocent headline can change what has to appear in the rest of the promotion.

The consumer credit rules are currently under review

In April 2026 the FCA consulted on simplifying parts of CONC 3, including existing rules around representative APR and representative examples. The consultation closed in June 2026. Check the live Handbook rather than assuming that older guides on consumer credit advertising remain accurate.

Comparisons, guarantees and "from" rates

CONC explicitly requires comparisons to be fair, balanced and meaningful. If your advert says customers save £300 a month by consolidating their debts, you should be able to answer:

• Compared with what?
• Over what period, and under which assumptions?
• Does total interest increase?
• Do fees apply?
• What proportion of customers actually achieve this?
• Is the customer's home now being used as security?

Without that context, a dramatic saving can create a very different impression from the economic reality.

Guaranteed outcomes are the obvious danger area. Guaranteed loan approval, guaranteed compensation, guaranteed returns, everyone accepted. The FCA has previously intervened where credit firms implied customers would receive credit regardless of their circumstances. If there is an eligibility assessment, an underwriting process or any uncertainty, advertising the outcome as guaranteed is difficult to justify.

Even softer wording deserves thought.

"Get approved today" promises an outcome. "Apply today" describes an action. That distinction matters.

Testimonials are still your claim

Consider a testimonial reading "they consolidated my loans and saved me £620 every month". You did not technically make the claim. Your customer did. But you chose to use that quote as marketing, so the promotion is still communicating that outcome to prospective customers.

Apply the same scepticism you would to a headline claim. Can you substantiate it? Is it typical? Will people infer they will get the same result? Are important qualifications missing? A quote mark is not a loophole.

"From" rates need to represent reality

Rates from 4.9% should not be treated as decorative copy. If the rate is only theoretically available to a very narrow group, consider what impression it creates for the audience actually receiving the advert. For applicable consumer credit products, detailed requirements around APR and representative rates can apply, which is why rate-led advertising needs proper compliance review rather than being handled as an ordinary marketing offer.

Make clear who the customer is dealing with

Financial lead generation often involves complicated commercial relationships. A typical journey looks like this:

1. Facebook advert branded BestLoans UK
2. Landing page branded MyLoanFinder
3. Lead generator, ABC Digital Ltd
4. Broker, XYZ Finance Ltd
5. Lender, another company entirely

That is not automatically a problem. But the customer should not be misled about who they are dealing with. Consumer credit guidance specifically identifies misleading customers into thinking a business is a lender when it is not as a potentially unfair practice.

If you are a broker, say so. If you are a lead generator, do not present yourself as the lender. If you introduce customers to third parties, make the relationship understandable.

Do not imply the FCA endorses you

Being authorised does not mean "FCA approved" in the sense most consumers would understand. The FCA regulates the firm. It does not endorse the company or recommend its products, and it has previously highlighted promotions implying endorsement as poor practice. Be careful with FCA logos, government-style design, official-sounding wording and references to schemes or compensation programmes. Your promotion should not look like it came from the regulator.

Lead generation is not outside the rules

This matters enormously to performance marketers. A business might say it does not provide loans, it just generates the leads. That does not put the marketing outside regulatory scrutiny. The FCA explicitly recognises communications designed to generate leads as communications that can fall within sector-specific financial promotion requirements. Claims management rules, for example, expressly cover communications intended to generate leads for the firm or another person.

Your funnel matters from the first advert, not from the moment a regulated broker picks up the phone.

Appointed Representatives need to know what their principal permits

An Appointed Representative operates under the responsibility of an FCA-authorised principal. That does not mean being on the FCA Register lets the marketing team run whatever it likes. The principal is responsible for overseeing its ARs and making sure they operate within the scope of their appointment, to the same standard it would apply to employees. Introducer Appointed Representatives are more restricted again, limited to introductions and distributing financial promotions.

If you are an AR, establish what your appointment permits, who approves your adverts, which templates can be used, whether changes require reapproval, which products you may promote, what regulatory wording is required and whether your lead generation partners are approved. Do that before the campaign launches, not after the principal's compliance team finds you in the Ad Library.

Affiliates and influencers are your problem too

Affiliate marketing is particularly dangerous because firms lose control of the message. FG24/1 says firms should take proactive responsibility for how affiliate marketers communicate their financial promotions. The regulator even says that where an affiliate creates content independently but uses the firm's referral link, the firm may still be regarded as causing the communication to be made.

So monitor affiliates and make sure partners understand the product and the regulatory requirements. Handing over a tracking link and telling someone to promote it however they want is asking for trouble.

The same applies to influencers, where the FCA has become considerably more aggressive. In 2026, seven influencers were sentenced after pleading guilty to issuing unauthorised financial promotions relating to a foreign exchange trading scheme. Later that year the FCA said an international crackdown had resulted in hundreds of social media takedown requests, with millions of UK users reached by suspected illegal promotions.

Using an influencer does not remove the financial promotion rules. It adds another person who can get the communication wrong.

Advertising should not look like independent advice

A particularly topical issue is content designed to read as impartial consumer guidance, such as someone announcing they just discovered a website that checks whether you are owed thousands from an old car finance agreement, when they have been paid by the claims company operating it.

In 2026 the FCA specifically criticised car finance claims ads that appeared to be neutral money tips while promoting commercial claims management businesses, and highlighted misleading use of well-known organisations, public figures and imagery to create false impressions of endorsement. If something is an advertisement, consumers should be able to tell.

The landing page is part of the promotion

Paid media teams sometimes send the advert to compliance and forget the page. The customer does not experience the advert in isolation. They experience the advert, then the landing page, then the form, then the email or SMS, then the phone call, then the sale. Consumer Duty expectations increasingly encourage firms to think about communications and customer understanding across that whole journey.

I would review the landing page for product claims, rates, fees, eligibility, regulatory status, the broker or lender relationship, risk warnings, representative examples, customer consent, comparisons, testimonials, form wording and what happens after submission.

The advert can be perfectly written while the landing page creates the regulatory problem.

Vulnerable customers and manufactured urgency

Financial advertising frequently targets situations associated with financial vulnerability: debt, poor credit, mortgage arrears, emergency borrowing, claims after financial harm, retirement, serious illness, bereavement. That does not mean those services cannot be advertised. It means firms should consider who is likely to receive the communication and whether the message could exploit or confuse vulnerable consumers. The Consumer Duty expressly expects firms to consider consumer understanding and support customers with characteristics of vulnerability.

Aggressive urgency is particularly hard to defend in those markets. "Act now before it's too late" might lift your click-through rate. That does not make it appropriate.

The same goes for countdown timers, offers ending tonight and three spaces left. If the deadline or the scarcity is genuine, fine. If the timer resets every time the page reloads, it is difficult to see how that supports a fair customer journey, and consumers here are usually making consequential decisions about borrowing, investments or long-term commitments.

Approval, records and the things performance teams change

There is a useful distinction between marketing review and regulatory approval. A PPC agency can identify obvious advertising risks. We can ask whether the claim is misleading, whether the risk warning is visible, whether the company is being represented accurately, whether the landing page contradicts the advert, whether the promotion is likely to cause problems at Meta, and whether the commercial message looks unbalanced.

What the agency cannot do is determine whether the promotion meets the rules applying to that particular financial product. That sits with the regulated firm's compliance process. So I would build campaigns in this order:

1. Marketing creates the concepts
2. Compliance reviews them
3. Marketing makes amendments
4. Authorised approval is recorded
5. The campaign launches

Regulatory sign-off should not be an informal message saying it looks okay.

Keep a record of what was approved

FG24/1 reminds firms that existing sign-off and record-keeping requirements apply to digital and social media exactly as they do to traditional formats. A sensible approval record covers the final copy, the final creative, the landing page, the approval date, the approver, a version number, the product, the intended audience, the mandatory warnings, any evidence supporting claims, and a review date where applicable.

This becomes critical when performance teams iterate quickly. If compliance approves version seven and somebody later duplicates the ad and trims half the warning to improve conversion rate, the live promotion is not the thing that was approved.

Small tests can be material changes

Performance marketers test constantly. Headline A, headline B, new image, new rate, different call to action, shorter copy. From a performance perspective those are routine optimisations. From a regulatory perspective they may materially alter the financial promotion.

Compliance approves "secured loans from 6.9% APRC, subject to status". Someone then tests "get the money you need from 6.9%". Same campaign, same landing page, very different communication. You need an approval process that accommodates experimentation without turning compliance into a bottleneck.

Common problems and what I would check

My pre-launch checklist

Before launching a financial services advert, this is what I would work through.

The legal position

• Is this actually a financial promotion?
• Who is communicating it, and are they authorised?
• If not, does it require approval, and is the approver permitted to give it?
• Does an exemption genuinely apply?

The product

• Which part of the Handbook applies: CONC, MCOB, COBS, ICOBS, CMCOB?
• Do product-specific warnings or disclosures apply?

The message

• Is every factual claim accurate, and can you evidence every number?
• Are the benefits balanced against material risks?
• Could the intended customer actually understand it?
• Have important qualifications been hidden or diminished?

Rates and costs

• Does an APR need to be displayed?
• Is a representative example triggered?
• Are fees included appropriately, and are "from" rates defensible?
• Does a comparison require more explanation?

The business identity

• Is it clear who the customer is dealing with?
• Is the business a lender, broker, introducer or lead generator?
• Is the FCA status stated accurately, without implying endorsement?

The creative

• Can customers actually read the warning?
• Does it survive mobile cropping and "see more"?
• Does the video display it for long enough?
• Does the first carousel card work without relying on later slides?

The landing page

• Does it make the same claims as the advert?
• Are relevant warnings, fees and conditions clear?
• Is the regulatory relationship understandable?
• Is the customer told what happens after submitting?

The audience and the approval

• Who is likely to receive this, and are vulnerable customers among them?
• Does the language put inappropriate pressure on them?
• Has someone with the correct authority approved the final version?
• Do the live advert and landing page match the approved versions?
• Does the performance team know what it may and may not change?

Conclusion

FCA compliance is not about filling adverts with legal disclaimers. It is about making sure customers receive an accurate and understandable picture of the product being advertised. Start with who is communicating the promotion, whether they are allowed to, and which rules apply to the product. Then look at the advertising itself: is the claim accurate, are the benefits balanced, are the risks prominent, could the intended customer understand it, does the landing page tell the same story, is the business relationship clear, and has the final version actually been approved?

Compliant does not have to mean boring

There is a temptation to believe there are only two options: high-performing advertising that compliance hates, or compliant advertising nobody clicks. I do not agree.

The job is not to remove the persuasion. It is to make the persuasion accurate. That is also why compliance needs to happen before the campaign is built rather than after it. Marketing produces 30 ads, compliance rejects 24, everybody gets annoyed is the worst possible workflow. Establish the requirements first, let the creative team design inside them, then review the finals.

The FCA looks at the communication consumers actually receive. Your marketing has to work inside that reality, not underneath it in the small print.

Additional resources

• FCA financial promotions and adverts
• FG24/1: financial promotions on social media
• FCA Consumer Duty
• FCA Handbook, CONC 3: consumer credit financial promotions
• FCA review of financial promotion approvers, May 2026

This article provides general marketing information and is not legal or regulatory advice. FCA requirements vary by product, business model and regulatory status. Firms should check the current FCA Handbook and obtain appropriate compliance advice before communicating financial promotions.

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