FCA financial promotions · financial promotions rules · UK
FCA financial promotions for marketers
FCA financial promotions rules shape what a fintech can say in an advert, an email, a website or a social post.
This guide sets out the financial promotions rules marketers meet most often, each linked to the FCA or legislation page it comes from.
GTM Quest is a GTM agency for fintech: we run campaigns with your compliance reviewers, and we do not give legal or regulatory advice.
Reviewed by GTM Quest · 27 October 2026 · 8 sources linked below
How a regulated campaign movesreview built in
- 01Brief and message libraryDAY 1CLAIMS · AUDIENCE
- 02Drafts and classificationWEEK 1COPY · CHANNEL
- 03Compliance reviewWEEKS 1 TO 2YOUR REVIEWERS
- 04Publish, record, monitorONGOINGLOG · CHANGES
Who approvesYour team
01/ the definition
What counts as a financial promotion? the FCA’s own words
Start with the definition, because the rules only bite on communications that meet it.
Module 01 / 05
The definition
Module 02 / 05
Many forms
Promotions can take a wide variety of forms, including print, broadcast or online adverts, marketing brochures, emails, websites and social media posts.
Module 03 / 05
Products covered
The FCA regulates advertising for most financial services, including loans, investments, cash savings and bank accounts, insurance, pensions, mortgages, payment services and e-money, and qualifying cryptoassets.
Module 04 / 05
Brand only
The FCA points firms to the Perimeter Guidance Manual, which sets out the legal definition of a financial promotion and what is merely a communication referencing the firm’s brand (image advertising).
Module 05 / 05
Any media
The FCA defines a promotion as an invitation or inducement to engage in investment activity (or claims management activity), communicated in the course of business.
Whether a particular piece of B2B marketing meets that definition is a question for your compliance team, so we classify every asset with them before it goes out.
02/ the rulebook
Where the FCA financial promotions rules sit by product area
On top of the general standard, financial promotions may need to comply with specific FCA rules, depending on the product type.
The list of sourcebooks comes from the FCA’s financial promotions and adverts page, which links to each one.
03/ the restriction
Financial promotions rules: the section 21 restriction who may communicate a promotion
Section 21 of the Financial Services and Markets Act 2000 is the reason approval matters to an unauthorised fintech.
Module 01 / 06
The restriction
Section 21(1) of FSMA says a person must not, in the course of business, communicate an invitation or inducement to engage in investment activity, or to engage in claims management activity.
Module 02 / 06
Authorised persons
Section 21(2) says the restriction does not apply if the person is an authorised person.
Module 03 / 06
Approved content
It also does not apply if the content of the communication is approved by an authorised person.
Module 04 / 06
Exemptions
The FCA notes the restriction also lifts where an exemption in the Financial Promotion Order 2005 (FPO) applies.
Module 05 / 06
Approver permission
The FCA says that as of 7 February 2024, firms need its permission to approve financial promotions for unauthorised persons, unless an exemption or the transitional regime applies.
Module 06 / 06
Checks before approval
Before a firm approves a promotion for an unauthorised person, it must confirm that the promotion complies with the financial promotion rules, including that it is fair, clear and not misleading.
Section 21 of FSMA restricts communicating an invitation or inducement to engage in investment activity unless the person is authorised or the content is approved by an authorised person.
Since 7 February 2024, approving promotions for unauthorised persons needs FCA permission, subject to exemptions.
04/ the workflow
How to build review into a fintech campaign so speed and compliance both survive
Agree claims and audience
Write down the claims you want to make, the evidence for each and who the campaign is aimed at.
Build an approved message library
Approved wording is reused across email, LinkedIn, ads and the website, so each new asset needs less review.
Ask whether it is a promotion
Your compliance team decides which assets are financial promotions and which rules apply.
Review and approve
Assets that need approval are approved by your compliance function or a permitted approver before they go out.
Publish and keep a record
Every published version is logged with its approval, channel and date.
Monitor and change
The FCA’s guidance for approvers covers ongoing monitoring of approved financial promotions, so changes go back through review.
This is how we run campaigns with clients’ reviewers; it is a working practice, not regulatory advice.
05/ consumer duty
Consumer Duty and consumer understanding what retail communications must do
Where communications reach retail customers, the Consumer Duty applies, including to firms that produce, approve or distribute financial promotions.
Module 01 / 06
Information needs
PRIN 2A.5.3R says a firm must support retail customer understanding so that its communications meet the information needs of retail customers.
Module 02 / 06
Likely to be understood
The same rule requires communications that are likely to be understood by retail customers.
Module 03 / 06
Effective decisions
Module 04 / 06
Clear, fair, not misleading
PRIN 2A.5.3R(2) says a firm must communicate information to retail customers in a way which is clear, fair and not misleading.
Module 05 / 06
Timing
PRIN 2A.5.5R says information must be given in good time, including before purchase and at suitable points through the product’s life.
Module 06 / 06
Channel
PRIN 2A.5.6R says a firm must satisfy itself that the communication channel supports effective decision making.
PRIN 2A.5.3R requires communications that meet retail customers’ information needs, are likely to be understood and equip them to make effective, timely and properly informed decisions.
Many B2B fintech campaigns never reach retail customers, but the ones that do need this standard built into the brief.
07/ how we work
How GTM Quest runs regulated campaigns your reviewers decide, we run the work
We are a marketing and go-to-market team, so the compliance decisions stay with you.
Module 01 / 05
Message library
We build the approved claims and wording once, then reuse them across channels.
Module 02 / 05
Review log
Every asset carries its reviewer, decision and date, so you can show what went out and why.
Module 03 / 05
B2B outreach
Account-based outreach to institutions and corporates, run as fintech lead generation with your compliance checks built in.
Module 04 / 05
Account programmes
Named-account programmes for a short list of institutions, through our ABM agency for fintech.
Module 05 / 05
No legal advice
We do not give legal or regulatory advice, and we do not approve promotions; your compliance function or a permitted approver does.
The full service is described on our fintech marketing agency page.
For account-based work, see account-based marketing for fintech.
08/ enforcement
What the FCA can do about a misleading promotion from its own page
The FCA lists what it can do when it finds that a financial promotion is misleading.
01
Change or remove
Ask the firm to change or remove the advert.
02
Write to customers
Ask the firm to write to customers who may have been misled.
03
Warn or fine
Warn or fine the firm.
04
Ban
Ban the promotion.
For complaints about taste, decency or social responsibility, the FCA points people to the Advertising Standards Authority.
09/ next step
Where are you now? pick your situation
What do you need?
Sector
Marketing across the sector
See financial services marketing agency work and our fintech GTM agencies guide.
15 minutes · video or phone
Book 15 minutes on a regulated campaign
Tell us your product, your buyers and how your compliance review works. We will tell you what we would run in the first week.
- 0115 minutes, video or phone
- 02A first-week campaign plan
- 03A written next step after the call
Pick a day that suits · live availability
10/ questions
FCA financial promotions FAQ
What fintech marketing teams ask about the rules.
An authorised person with FCA permission to approve, unless an exemption applies; the FCA says this permission has been needed since 7 February 2024.
Not necessarily.
The FCA points firms to the Perimeter Guidance Manual for the legal definition and for what counts as image advertising; your compliance team should decide.
No. We run campaigns with your compliance reviewers and do not give legal or regulatory advice.
We start the GTM motion on day one and build the system around it in weeks 1 to 4.
Taking on new clients
Regulated campaigns with review built in
Fifteen minutes is enough to plan the first week.
12/ sources
Every source on this page
Each figure above links to one of these. All were opened and checked on 27 October 2026.
- a financial promotion is an invitation or inducement to engage in investment activity (or claims management activity), that is communicated in the course of businessfca.org.uk
- regulates advertising for most financial servicesfca.org.uk
- COBS 4.2, fair, clear and not misleading communicationshandbook.fca.org.uk
- Section 21(1) of FSMAlegislation.gov.uk
- as of 7 February 2024, firms need its permission to approve financial promotions for unauthorised personsfca.org.uk
- produce, approve or distribute financial promotionshandbook.fca.org.uk
- FG24/1 guidancefca.org.uk
- FG23/3fca.org.uk
06/ social media
Financial promotions on social media firm posts and influencer posts
The FCA's FG24/1 guidance sets out its expectations for promotions on social media, including by influencers.
→ Treat any social post about a regulated product as a promotion until your compliance team says otherwise.
FG24/1 says the FCA's financial promotion rules are technology neutral and apply across all channels used to advertise, including social media.
It also says unauthorised persons, such as social media influencers, who promote a regulated financial product or service without approval of an appropriate FCA-authorised person may be committing a criminal offence.
For cryptoassets, FG23/3 sets out the FCA's expectations, and the FCA says it has been supervising firms against the cryptoasset promotions regime from 8 October 2023.