Financial Services Compliance Blog - Thistle Initiatives

FG24/1: Finalised guidance on financial promotions on social media

Written by Matthew Williamson | Apr 23, 2024 9:19:56 AM

Summary 

We clarify our expectations on how financial promotions should be communicated on social media. We also summarise and respond to feedback to GC23/2.

Why we are issuing this guidance

We want to clarify our expectations for when firms and others, such as influencers, use social media to communicate financial promotions and address emerging consumer harm we’ve seen arising from the use of social media.

Financial promotions on all advertising channels should be fair, clear and not misleading, and support consumer understanding. Our financial promotion rules are technology-neutral and apply across all channels used to advertise, including social media.

We want firms to ensure that promotions provide a balanced view of the benefits and risks and clearly communicate information that will help consumers make effective, well-informed decisions.

Unauthorised persons, such as social media influencers, who promote a regulated financial product or service without the approval of an appropriate FCA-authorised person may be committing a criminal offence. We also include perimeter guidance to provide additional clarity on when communication might constitute a financial promotion.

This Guidance will be relevant to:

  • Authorised persons involved in communicating or approving financial promotions on social media.
  • Unauthorised persons, including influencers or other affiliate marketers, are involved in communicating financial promotions on social media.
  • Trade bodies that represent the above groups.

Background 

Social media is an increasingly important part of firms’ marketing strategies and has allowed them to reach a large audience with greater speed and frequency than ever before. However, poor quality financial promotions on social media can lead to significant consumer harm due to their wide reach and the complex nature of many financial products and services.

In 2023, we consulted on updated guidance for financial promotions on social media. We are replacing our previous Guidance (FG15/4) with this Guidance, after making some targeted amendments following consideration of the feedback we received.

This Guidance does not create new obligations for those who promote financial products and services on social media. It indicates how they might approach complying with their existing regulatory obligations. For unauthorised persons, including influencers or other affiliate marketers, the Guidance explains when their communications might fall within our regulatory perimeter and how our rules apply to their activities.

Links: https://www.fca.org.uk/publications/finalised-guidance/fg24-1-finalised-guidance-financial-promotions-social-media