FCA review finds weak standards among financial promotion approvers
FCA review found some s.21 financial promotion approver firms failing Consumer Duty standards, including approving unsubstantiated claims and misdirected retail promotions.
The review reinforces FCA's Consumer Duty expectations on promotion approvers. Firms approving promotions for third parties should expect targeted supervisory follow-up, with elevated risk of permission variation or enforcement where retail consumers are exposed to inappropriate marketing.
Direct conduct risk implications for s.21 approvers and firms relying on approved third-party promotions.
Action Required
Strengthen s.21 approver governance, audience targeting controls, and substantiation evidence for all approved promotions.
Promotion approver standards are a strategic FCA Consumer Duty priority with enforcement implications.
Review s.21 approval policies, evidence files, and audience verification controls. Embed Consumer Duty checks from inception of approval process and document outcomes-based testing of approved promotions.
“Firms that approve financial promotions should be doing more to protect consumers, an FCA review has found. The FCA found some firms approved adverts with unsubstantiated claims or allowed retail investors to see promotions intended for professional clients.”