FCA Findings: Those Approving Financial Promotions must do more

Avid readers of the FCA’s regulatory round-up email may have seen their release in relation to approving financial promotions.

On 27 May 2026 the FCA published findings of a review of firms who approve the financial promotions of unregulated firms. Whilst the FCA’s sample size was quite small (only 10 firms) they found “that some firms approved adverts with unsubstantiated claims or allowed retail investors to see promotions intended for professional clients. In some cases, firms relied on third-party templates instead of doing proper checks themselves”.

The warning is clear:

• Those with permissions to approve the promotions of other firms must take those responsibilities seriously

• An established process is required ensuring the promotion is reviewed by competent individuals against the relevant section of the FCA Handbook for that promotion type (such as COBS 4) and the Consumer Duty

• The Consumer Duty element of the review checks the proposed promotion to ensure it provides the right information to enable customers to make an informed decision and that this information is presented in a way that is understandable for the target market

• Recently the FCA has focused its attention on balance within promotions, meaning the risks of the product should be as clear as the intended benefits – for guidance see the FCA’s social media guidance: FG24/1: Finalised guidance on financial promotions on social media | FCA

• Testing should support the Consumer Duty element of the review, as with any other customer communication under the Duty

• The ‘back-stop’ check is that firms must make sure every promotion they sign off is fair, clear and not misleading

Here is the FCA’s review: Review of financial promotion approvers finds some firms need to raise standards | FCA

To support, we have developed a checklist which can be used for each promotion, ensuring compliance with the FCA’s expectations. The checklist is appropriate for those approving the promotions of other firms as well as those approving their own. It can be downloaded here: Financial Promotions Templates | RB Compliance Consultancy