Search for FCA compliant marketing and the top results are the FCA, two law firms and a compliance software vendor. Marketing agencies barely appear. That is a fair reflection of the problem: in financial services, marketing is a regulatory exercise that happens to involve creative work, rather than the other way round.
This guide covers the rules that decide what is possible before any campaign is designed, the one in the FCA's social media guidance that quietly breaks most social marketing, and what still works inside the constraints.
The constraint is who may speak, not what may be said
In most regulated sectors the restriction is on claims. Here it is on communication itself. Under section 21 of the Financial Services and Markets Act 2000, a financial promotion must be made or approved by an authorised person. That covers almost any invitation or inducement to engage in investment activity.
Two changes since 2024 have tightened it considerably.
| Change | From | Effect |
|---|---|---|
| Section 21 approval gateway | 7 February 2024 | An authorised firm now needs specific FCA permission to approve promotions for unauthorised persons. The old route of finding any willing approver has largely closed. |
| FG24/1 social media guidance | March 2024 | Replaced FG15/4. Sets out how the promotion rules apply on social, including to influencers and affiliates. |
Enforcement has moved with it. In its 2024 data the FCA reported 19,766 financial promotions amended or withdrawn by authorised firms, against 10,008 in 2023. That is a rise of 97.5 per cent in a single year. Around 8 per cent came from the FCA's own proactive reviews rather than complaints.
The rule that breaks most social media marketing
FG24/1 requires financial promotions to be standalone compliant. Each communication must comply with the rules when considered on its own.
Read that against how social content is normally built and the problem is obvious. You cannot put the benefit in the image and the risk in the caption. You cannot rely on someone tapping “see more”. You cannot run a carousel where slide one sells and slide five warns. You cannot link out to the risk disclosure and treat that as covered.
Every individual post, story, reel and ad has to carry a balanced view of benefits and risks within itself.
| Common approach | Why it fails standalone compliance |
|---|---|
| Risk warning in the caption below the image | The image is the promotion and must comply alone |
| Disclosure behind a “see more” expander | Requires an action the consumer may not take |
| Carousel with warnings on the final slide | Slide one is a promotion in its own right |
| Link to a risk page in the bio | Off-post material does not cure an on-post breach |
| Short video with risks in the description | The video is assessed on its own |
The practical consequence is that financial services social content has to be designed compliant rather than made compliant afterwards. A creative team producing work and sending it to compliance at the end will produce work that gets rejected at the end.
Influencers and affiliates carry criminal exposure
This one is worth stating plainly because the commercial temptation is real. An unauthorised person who communicates a financial promotion without approval from an appropriately authorised firm may be committing a criminal offence.
That is not a compliance breach with a fine attached at the end of a process. It sits in a different category, and the firm behind the arrangement is exposed alongside the individual.
FG24/1 is explicit that firms using affiliates or influencers must ensure those people understand the product, understand the regulatory requirements, and are appropriately approved and monitored. Signing a contract and hoping is not monitoring.
Consumer Duty turned communication into an evidence problem
The Consumer Duty has applied since July 2023 and requires communications to be timely, clear and capable of being understood, as part of delivering good outcomes for retail customers.
On 13 March 2026 the FCA published its review of how firms are handling consumer understanding, covering management information and testing, communication design, vulnerability and accessibility, financial promotions, and governance. The expectation it set out is that design choices should be evidence based and tested with diverse customer groups, rather than signed off on judgement.
That is a marketing requirement written as a regulatory one. Customer testing moves from something good teams do to something a firm should be able to evidence when asked.
The direction elsewhere is toward simplification. On 29 April 2026 the FCA published CP26/15, proposing to strip duplicative and overly prescriptive promotion rules from the consumer credit sourcebook on the basis that the Duty now covers the ground. Fewer boxes, more responsibility for the outcome, which is harder rather than easier.
What works inside the constraints
The constraints remove the fastest and laziest tactics and leave the ones that build a practice.
- Search. The strongest channel here. Someone searching for advice on a pension transfer has declared intent, and a page can carry balanced risk information in a way a social post cannot.
- Educational content. Explaining a product honestly, including who it suits badly, is both compliant and the most effective trust building available in a sector where trust is the entire purchase.
- Existing client communication. Lower regulatory friction and higher return than most acquisition activity. Consistently under-invested.
- Professional referral. Accountants, solicitors and existing clients. Slow, and it produces the best clients most firms have.
- Paid search. Workable with tight control of ad copy, sitelinks and landing pages, since each is a promotion in its own right. Every element is a promotion.
- Social. Usable for the firm, the people and the thinking. Difficult for products, for the standalone reason above.
Where the sector actually is
For context on the market itself, financial and related professional services contributed £290 billion of gross value added in 2025, about 11 per cent of the UK total, and employ almost 2.5 million people. Our UK Financial Services Industry Report reconciles that against the commercial market size estimates, which differ by nearly two to one because they are quietly measuring different things.
What we see go wrong
- Compliance treated as the final gate rather than the brief, producing work that gets rejected late and expensively.
- Social content built with the benefit in the creative and the risk in the caption, which fails standalone compliance.
- Influencer and affiliate arrangements entered without checking who is approving the promotion.
- Approval treated as a one time event, when a promotion has to remain compliant for as long as it is live.
- No record of customer testing, at a point where the FCA expects communication design to be evidence based.
- Generic agencies applying tactics from unregulated sectors, which is how most of the 19,766 amendments happen.
How we work with financial services firms
Compliance in the brief rather than at the end, so creative work is built to survive review instead of being rebuilt after it. Search and content that can carry balanced information properly. Review cycles for live promotions rather than one time approval. And an honest view of which channels are worth the regulatory friction, which for most firms means fewer than they are currently running.
Tell us what is not working and we will give you an honest answer, including when the answer is that the marketing is fine and the approval process is the bottleneck.
Sources
- Financial Services and Markets Act 2000, section 21. Approval gateway in force 7 February 2024.
- Financial Conduct Authority. FG24/1, finalised guidance on financial promotions on social media, March 2024, replacing FG15/4.
- Financial Conduct Authority. Financial promotions data 2024, published February 2025.
- Financial Conduct Authority. Consumer understanding, good practice and areas for improvement, 13 March 2026.
- Financial Conduct Authority. CP26/15, simplifying financial promotions rules in CONC 3, 29 April 2026.
- TheCityUK. Key facts about UK-based financial and related professional services, June 2026.
Rules and guidance change. This guide was last reviewed in July 2026. If something here is out of date, tell us and we will correct it and note the change.
