The s21 restriction in plain terms (and why it’s criminal)

The 2024 approver gateway and the three exemptions

The cryptoasset promotion window: 30 Sep 2026 – 28 Feb 2027

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Financial Promotion & s21 Guide

approver gateway · exemptions · crypto deadline

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The rule that carries criminal liability

Section 21 of FSMA says that, in the course of business, you must not communicate an invitation or inducement to engage in investment activity unless you are FCA-authorised, or the content has been approved by an authorised person who holds the right permission. Get it wrong and it isn’t just a rulebook breach — it’s a criminal offence.

Since 2024, not every authorised firm is allowed to approve promotions. A firm without approver permission simply cannot lawfully approve your marketing — however willing it is.

Which side of the gate are you on?

The guide sorts you into your situation and shows the obligation that follows — whether you need approver permission, an approver, or an exemption.

You may need the gateway — or an approver

• Unauthorised and want to promote an investment to the public
• Authorised and want to approve promotions for third parties as a service
• Relying on an approver but haven’t confirmed they hold permission
• What the guide explains
• The 2024 approver gateway and who it caught
• The three exemptions — and how the FCA polices their misuse
• What approval actually commits an approver to, on an ongoing basis
• The cryptoasset promotion timetable you can’t ignore
• We advise both sides of the gate

Whether you need approver permission, need your promotions approved to the right standard, or need exemption analysis pressure-tested before a promotion goes out — that’s exactly the work we do.

Get the Guide

This guide is general information about the financial promotion regime as at 2026 and is not legal or regulatory advice for your specific circumstances. The Section 21 restriction is a serious matter with potential criminal liability; for advice tailored to your firm, speak to us directly.

Compliance Consultant

UK 0800 689 0190 · Int’l 0208 243 8620 · complianceconsultant.org

© Compliance Consultant. Trading name of UK Compliance Consultant Limited. All guidance is general information and subject to a final compliance-oversight review before reliance.