The FCA has just published the results of a multi-firm review into section 21 financial promotion approvers, and the findings aren't pretty. Several firms have been told to stop approving new promotions immediately, and the regulator has made clear it's watching this space closely.
For IFAs who use third-party approvers for their marketing materials—or who approve promotions themselves—this review contains some pointed warnings worth understanding.
What the FCA Actually Found
The review examined firms authorised to approve financial promotions under section 21 of the Financial Services and Markets Act. These are the gatekeepers who sign off marketing materials for unauthorised firms, but also frequently work with smaller authorised firms who want an extra layer of compliance checking.
The FCA found that some approvers:
- Failed to properly assess whether promotions were fair, clear, and not misleading
- Didn't have adequate systems to monitor the promotions they'd approved
- Lacked sufficient expertise in the products they were approving
- Took on more work than they could properly resource
Lucy Castledine, the FCA's director of consumer investments, put it bluntly: "When approvers fail in their responsibilities, people can be misled into harmful financial decisions."
Several firms have been told to stop approving new promotions while they fix their processes. Others have been placed under enhanced supervision.
Why This Matters for IFAs
You might think this is primarily a problem for the approval firms themselves. But the implications run deeper.
If you use a third-party approver: The FCA has made clear that using an approver doesn't transfer your responsibility. If the promotion is misleading, you're still on the hook. The regulator expects you to have done your own due diligence on any approver you use—checking their expertise, their processes, and their track record.
Asking "are you FCA authorised?" isn't enough anymore. You need to understand how they assess promotions, what their turnaround times mean for thoroughness, and whether they have genuine expertise in the products you're promoting.
If you approve your own promotions: The standards the FCA applied to these approver firms apply equally to you. Every social media post, every email newsletter, every PDF factsheet needs to meet the fair, clear, and not misleading test. The review found firms approving promotions without properly understanding the underlying products—a trap that's easy to fall into when you're busy and a post seems straightforward.
If you're promoting higher-risk investments: The FCA specifically called out concerns about promotions for complex or high-risk products. If you're involved in anything beyond vanilla investments—structured products, alternative assets, anything with a complex risk profile—expect heightened scrutiny of your marketing materials.
The Social Media Connection
This review doesn't exist in isolation. The FCA has been systematically tightening its grip on financial promotions across all channels, with social media getting particular attention.
The regulator recently took legal action against seven financial influencers for unauthorised social media posts. Research cited in the enforcement action found that 1 in 10 finance ads on Meta targeting UK users were scams, with Brits losing an estimated £44 million to fraudulent social media promotions.
The connection is direct: weak approval processes let poor-quality promotions through, which harms consumers and erodes trust in legitimate advisers.
Practical Steps to Take Now
Review your approver relationship. If you use a third-party approver, ask them directly about the FCA's review findings. How do they ensure they have expertise in the products you promote? What's their monitoring process after approval? A good approver will welcome these questions.
Audit your recent promotions. Look at your last three months of social media posts and marketing materials. Would each one pass the fair, clear, and not misleading test if the FCA examined it tomorrow? Pay particular attention to any posts about investment performance, charges, or risk.
Document your process. The FCA wants to see that you have a system, not just good intentions. Write down how you assess promotions before publishing. Keep records of what you checked and when.
Be especially careful with social media. The informal nature of platforms like LinkedIn and Twitter makes it easy to dash off a post without proper consideration. But the FCA applies the same rules to a tweet as to a glossy brochure. Character limits don't exempt you from compliance requirements.
The Direction of Travel
This review is part of a clear pattern. The FCA is investing more resources in financial promotion supervision, using technology to monitor social media at scale, and taking enforcement action more readily than in the past.
The days of treating compliance as a box-ticking exercise are over. The regulator wants to see genuine understanding of the rules and meaningful processes to apply them—not just a signature from an approver who glanced at your content for thirty seconds.
For IFAs, this means building compliance into your marketing workflow rather than treating it as an afterthought. The firms that do this well will avoid regulatory problems and build stronger client relationships. Those that don't will eventually find themselves explaining their social media posts to the FCA.
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