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FCA Gateway For Approving Unauthorised Financial Promotions

What has happened?

The FCA announced in September 2023 that regulated firms approving financial promotions for unregulated firms will have to demonstrate they have the necessary skills and expertise to do so. Firms granting such approvals must understand the product, to ensure that the promotion is accurate and fairly balances risk and reward. 

What are the key points?

Previously, any FCA authorised firm could approve promotions on behalf of unregulated firms. The FCA’s belief is that this practice has caused harm, with firms approving promotions for products they do not understand, as well as promotions that are unclear, unfair, or misleading.   

Firms will need to apply to the FCA gateway for “approver permission” between 6 November 2023 and 6 February 2024 to continue approving promotions ahead of the new rules coming into force on 7 February. Firms that have submitted an application can continue to approve promotions after this window until they receive a decision on their application.  

Application forms detailed here will be available for completion once the application window opens in November 2023. The relevant Variation of Permission form can be accessed via Connect (for already authorised firms) or via a link here (for firms whose application is under consideration).

Firms approving financial promotions for unauthorised firms will be shown on the Financial Services Register and they will also be required to report regularly on what they sign off and on any promotions of concern that they cancel approval for, to help the FCA to move faster to remove rogue promotions. 

FCA authorised firms will be able to approve financial promotions for unauthorised members of their group and their appointed representatives and in such cases will not need to apply for approver permission.

How can we help you obtain the FCA permission to approve financial promotions? 

Thistle Initiatives has supported firms for over 10 years as a trusted compliance and regulatory advisor. In addition to assisting you as-and-when, our team of specialists can serve as your right hand in meeting and complying with regulations. We understand the importance of staying up-to-date and compliant and are dedicated to providing the guidance and support needed to do so.

Are you looking for help with your financial promotion approval arrangements, or more general regulatory questions? Contact our specialist team now to schedule a free consultation. Get in touch with us by calling 020 7436 0630 or sending an email to