The FCA is cracking down on financial promotions - many are not ready

Financial promotions are everywhere, and for many businesses they have become just another part of everyday marketing. The problem is that promoting finance is not just marketing - it can amount to regulated activity, and the Financial Conduct Authority is taking a much closer look at how businesses are getting it wrong.

This scrutiny is no longer limited to traditional financial services. Any business offering finance to customers may fall within scope, which means expectations around compliance, clarity and transparency have risen across multiple sectors. Many firms still rely on outdated assumptions about what is acceptable, and that is exactly where the risk lies.

This is not new regulation. It is a shift in enforcement, with the FCA applying existing rules more closely and more consistently.

What the FCA means by ‘financial promotions’

A financial promotion is any communication that invites or induces a customer to engage in a regulated financial activity. In practice that includes website content, social media posts, paid ads, email campaigns and in-store signage. The rules for credit promotions sit in CONC 3 (opens handbook.fca.org.uk in a new tab) of the FCA Handbook.

It is no longer limited to formal adverts, and most businesses do not realise they are already making them.

Why the FCA is enforcing more closely now

There is no single reason. A combination of trends has made poor financial promotions a bigger risk to consumers.

Consumer Duty. The FCA introduced it to raise the standard for how businesses treat customers, and it requires firms to act to deliver good outcomes rather than merely avoid being misleading. Marketing is often the customer’s first contact with finance. If it is unclear, unbalanced or misleading, the customer starts from a bad position - which is likely to be considered a failure under the Duty.

Online and social media marketing. Businesses can now promote finance across many platforms. The informal tone of Facebook, Instagram and TikTok encourages a relaxed attitude to compliance, short-form content makes it easy to omit key information, and the pressure to post quickly means less oversight. Consumers increasingly make decisions from quick, surface-level content, which raises the risk of misunderstanding.

Buy now, pay later and embedded finance. Finance is now built into everyday purchases, appearing at retail checkouts, in online shopping and in service businesses. Customers are offered credit instantly with minimal friction, and it can start to feel like a normal payment option rather than a credit agreement. Key information gets overlooked. Buy now, pay later has historically faced less direct regulation, and rapid growth has raised concerns about consumer understanding.

Poor practice across sectors. The FCA has seen businesses highlight benefits, downplay or omit key information, and use vague language. Promotions that are technically presentable but not clear, balanced or properly explained. Most of this is not deliberate - firms either do not understand the rules or assume what they are doing is fine. Repeated across thousands of businesses, small issues create widespread consumer risk.

Where businesses are getting it wrong

Misleading or incomplete messaging

Benefits highlighted without the risks set out equally clearly, affordability over-promised, and key terms left unexplained.

Missing or incorrect representative APR

A representative APR is required in many financial promotions depending on how the offer is presented. It is often missing, hidden or incorrectly calculated - a major compliance failure.

Misuse of ‘0% finance’

Presented as free without context. Without explanation of eligibility or conditions, it can mislead.

Social media content

The informal tone of many platforms leads to relaxed compliance. Stories, reels and captions still count as promotions, and influencer or third-party content carries the same risk.

Website compliance

Finance messaging scattered across multiple pages, leaving key information missing or unclear, with disclaimers that are neither visible nor effective.

Most of these issues are unintentional. They are still breaches, and they still require correction.

The gap between what businesses think is compliant and what actually is

Most businesses do not intend to mislead. The FCA is interested in whether a consumer could clearly understand what is being offered. The standard is that promotions must be clear, fair and not misleading - clear meaning easy to understand, fair meaning balanced and unbiased, and not misleading meaning free of hidden implications.

What happens if you get it wrong

The FCA can require promotions to be withdrawn or amended. It can issue warnings, impose fines, and restrict business activity where it judges that necessary. Beyond the regulatory consequence there is reputational damage and disruption to the sales process.

This applies to any business issuing or communicating promotions, whatever its size. Small businesses are not exempt because they are less visible than their larger competitors.

What this means for you

Review your financial promotions across your website, social media and advertising. Check APR accuracy, the clarity of the messaging, and the visibility of key information. Put internal processes in place so compliance sees content before publication, and treat it as an ongoing process rather than a one-off exercise.

None of the rules here are new. The FCA is enforcing them more firmly. If your marketing involves finance, it is no longer just marketing - it is regulated activity.