Why your website could be your biggest compliance risk

Most businesses worry about FCA inspections, paperwork and customer complaints. One of the biggest compliance risks is often sitting in plain sight on their own website.

Websites are updated regularly with little thought given to compliance, and web teams often make changes without understanding the FCA rules on financial promotions. A seemingly minor update can unintentionally create a significant compliance issue. Unlike a printed advert, a website is constantly evolving - every time a page is updated, a banner is added or finance wording changes, there is the potential to create a fresh financial promotion that should be reviewed. The FCA has made clear that financial promotions remain an area of focus across multiple sectors.

Why websites have become a compliance hotspot

Websites are in the FCA spotlight because they are rarely static. Businesses regularly update homepage banners, offers, blogs and pop-ups, and every one of those updates has the potential to become a financial promotion.

The risk comes from how the work is divided. Web teams focus on generating enquiries, increasing conversions and improving click-through rates. Compliance is responsible for ensuring communications meet regulatory requirements. Unless both work together, mistakes happen. The two often collaborate when a site is first built, then forget to check when uploading a small change.

The disclaimer myth

One of the most common misconceptions is that adding a disclaimer solves every compliance problem - that a few lines of small print licence whatever headline claim you like. “Terms apply”, “subject to status” or “representative APR applies” is not enough on its own.

The FCA expects financial promotions to be clear, fair and not misleading, with important information presented prominently rather than hidden away. The rules for credit promotions sit in CONC 3 (opens handbook.fca.org.uk in a new tab) of the FCA Handbook. A disclaimer can clarify information; it cannot correct a misleading headline. Firms should not bury key information in footnotes or obscure text.

Social media is no longer the Wild West

Social media once seemed a more relaxed platform. The FCA now applies exactly the same principles, and set this out in its finalised guidance on financial promotions on social media, FG24/1 (opens fca.org.uk in a new tab), published in March 2024. Whether the promotion appears on Facebook, Instagram, LinkedIn, TikTok or X, the same standards apply.

Representative examples and APR

Many businesses advertise monthly payments, interest rates or finance offers without understanding when a representative example is required.

A representative example gives consumers the information they need to understand the true cost of borrowing - the representative APR, cash price, deposit and total amount payable, along with the duration and amount of repayments. Not every finance advertisement requires one. Whether it applies depends on how the finance is promoted and what information the advertisement already includes.

Common website mistakes

A frequent problem is advertising finance on a homepage banner, or linking customers to an application form, without including the information the FCA requires customers to see clearly and prominently before they click. Where key finance information, representative examples or required risk information are missing or insufficiently prominent, the promotion can fall short of expectations.

Another is product pages displaying finance options while the representative information is missing or hard to find.

Mobile deserves particular attention. Limited screen space means important information can end up hidden, requiring excessive scrolling, or set in a font too small to read comfortably. Mobile optimisation matters for compliance, not only for SEO.

The growing influencer problem

Influencer marketing has expanded into many sectors, with businesses working with a wide range of creators and ambassadors. Where those individuals promote finance on behalf of the business, the FCA rules still apply. The business remains responsible for ensuring the promotion complies - creators cannot simply say what they like when promoting finance.

This holds whether the subject is vehicle finance, cosmetic procedures, home improvements or retail finance.

Why internal approvals matter

Many compliance issues happen because marketing creates content that compliance never sees. Thorough approval processes matter, alongside documented sign-off and version control. Periodic website reviews catch what has slipped through. Compliance should happen before publication, not after it.

What businesses should be doing now

• Audit website and social media output for anything that constitutes a financial promotion.
• Review finance wording, banners and landing pages.
• Check representative examples are present where required, and prominent where present.
• Review disclaimers - what they clarify, and what they may be doing work to conceal.
• Train marketing teams and sales staff, so the judgement happens before publication.

What this means for you

Websites are living documents, and every update carries the potential to introduce a new compliance risk. Relatively small marketing changes can have significant regulatory consequences, which is why financial promotions should never be an afterthought. Regular reviews, robust approval processes and close collaboration between web and compliance teams identify issues before they become regulatory problems.

Your website is often the first place a customer encounters your finance offering. It should create the right impression for the customer and for the regulator.