FCA Financial Promotions Checklist for Marketers

Why run a checklist at all?

The FCA acts on this at scale. It had 19,766 promotions amended or withdrawn in 2024, up 97.5% on 2023, and issued 2,240 alerts about unauthorised firms and individuals. In February 2026 it announced sentences for seven influencers over promotions of an unauthorised forex scheme.

Work through the five parts below in order. Parts 1 and 2 apply to everything. Part 3 depends on your product. If you stop at a "no", the asset goes to compliance.

We took the Handbook references from FCA pages in November 2026. Rule numbers can change, so have your compliance team check each one against the live Handbook before you rely on it.

Part 1: May this be communicated at all?

Section 21 of FSMA comes first, because a perfect advert from the wrong person can still be illegal.

1. Is it a financial promotion? The FCA's Perimeter Guidance Manual holds the legal definition. Ask compliance if you are unsure. Treat anything that encourages someone to take up a financial product as a likely yes.
2. Who is communicating it? Name the legal entity.
3. Is that entity authorised for this? Check the FCA Register, and note the permission.
4. If not authorised, who approved it? A firm can approve a promotion for an unauthorised person only with FCA permission, unless an exemption applies.
5. Does an exemption apply? The FCA lists three for approvers: promotions prepared by the firm's appointed representatives, by unauthorised persons in its corporate group, and an authorised person's own promotions communicated by an unauthorised person.
6. Is the approval specific and recorded? Approving for general legality is not enough.
7. Is ongoing monitoring planned? Approvers must keep checking approved promotions.

A promotion from an unauthorised person with no approval or exemption can be a criminal offence. The FCA is direct about this with influencers.

Part 2: Does the content pass?

These tests apply on every channel. The FCA says its rules are media-neutral.

Use the FCA's practical test too: put yourself in the customer's position, and ask what they need to know at this stage of the journey.

Part 3: Which product rules apply?

Now add the rules for your product.

Crypto firms should also follow the timetable. The FCA's authorisation gateway opened on 30 September 2026, applications run to 28 February 2027, and the regime starts on 25 October 2027. The FCA's page on s.21 approvers explains how your promotion route depends on when you apply, so read it before you plan 2027 campaigns. PS23/6 also bans incentives to invest (COBS 4.12A.7R), so check any referral or welcome offer against it.

For CFDs, a firm with no retail trades in the previous 12 months uses a different warning, stating that the vast majority of retail accounts lose money.

Part 4: Social media and affiliates

Social adds its own failure points, because formats truncate text and third parties write the copy. FG24/1 is the guidance to read, and it replaced FG15/4 in March 2024.

1. Does the risk warning remain visible in the format used?
2. For high-risk investments, does the prescribed warning show throughout, without being cut off by the platform?
3. Does each frame of a video or carousel stand up on its own?
4. Is paid content labelled as advertising up front, including affiliate links? The FCA points to the ASA's expectation on this.
5. Have you checked the marketing restrictions for this product on this platform?
6. Could the content exert undue pressure on vulnerable readers?
7. Do you know every affiliate promoting you?
8. Has each affiliate's content been approved, and is it being monitored?

The FCA says firms working with affiliate marketers should take proactive responsibility for their affiliates' promotions. Our guide on how to build a forex affiliate program shows how to structure that, and the same controls suit other products.

Part 5: Records and follow-up

Assume someone will ask about this asset in two years.

1. Is the final version saved, exactly as published?
2. Are the date, channels, audience and approver recorded?
3. Is the evidence behind each claim on file?
4. Is there a date for the next review?
5. Is there a named owner for withdrawing it?
6. Do you track complaints linked to this campaign?
7. Has the Consumer Duty evidence been updated, if relevant?

Retention periods vary by product and firm type, so take the period from your compliance team. A simple workflow automation can capture most of these fields at the moment of approval, which beats rebuilding them later from email threads.

Four myths the FCA has corrected

The FCA's mainstream investments page clears up some common beliefs. These points apply to mainstream products only, so confirm your product fits before relying on them.

• "Capital at risk" is not mandatory wording.
• Mainstream promotions do not need a separate risk warning, though they must give a balanced view.
• Risks do not have to come first.
• Warnings do not have to appear on every page of a journey.

The FCA also notes that consumers often do not read "capital at risk" statements, and it supports contextual risk statements that explain benefits and risks together. Plain writing is often both clearer and safer than another line of small print.

Next step

Save this page as your template, and ask compliance to mark up what they would change for your firm. Then run it on your three busiest live assets. If you also market into the EU, read our guide to MiFID II marketing communications, since the two regimes look alike and differ in detail. Crypto firms should read our crypto marketing strategy next. For search work done to this standard, see our fintech and forex SEO service.