The challenge

The financial promotions regime has tightened sharply — the gateway for approving promotions, stricter rules for high-risk investments, and the finfluencer crackdown have all raised the stakes. Under the Consumer Duty, every promotion must also be fair, clear and not misleading in outcome, not just in wording. Firms and the marketers they work with are getting caught out.

What’s inside

✔ A practical, run-before-you-publish checklist for any financial promotion

✔ The ‘fair, clear and not misleading’ test applied to real-world content

✔ Social media and finfluencer-specific pitfalls — and how to avoid them

✔ Record-keeping and sign-off expectations under the s.21 regime

✔ Where the Consumer Duty raises the bar beyond the letter of COBS/CONC

Who it’s for

Regulated firms promoting their own products, firms approving promotions for others, and non-regulated businesses (including marketing agencies and finfluencers) who need to understand the rules.

The benefit to you

You’ll be able to sign off promotions with confidence — knowing each one passes the test before it ever reaches a customer.

Key sources: FSMA 2000 s.21; the FCA’s financial promotions rules (COBS 4 / CONC 3); FG24/1 guidance on financial promotions on social media.

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This is only generic advice and does not constitute legal or regulatory advice. Please seek professional assistance for any specific cases, files or situations.