GuidanceRegulated IndustriesFinancial Services
Regulated Industries

Financial Services

FCA regulations, financial promotions, and what copywriters need to know when writing for banks, insurers and investment firms.
6 min readReviewed January 2026Annual review
This UK-focused information is not legal advice.

Key points

  • Financial promotions must be fair, clear and not misleading
  • The FCA regulates advertising for most financial products and services
  • Risk warnings and disclaimers are legally required
  • Copywriters may be held responsible for non-compliant promotions

What the Code says

The Code of Practice requires that we “comply with all relevant advertising codes and regulations” and recognise that “certain sectors have additional regulatory requirements.”

Financial services is one of the most heavily regulated sectors for marketing communications. Getting it wrong can result in FCA action against your client — and potentially against you.

Who regulates financial promotions?

Financial promotions in the UK are regulated by:

  • Financial Conduct Authority (FCA) — the primary regulator for financial services marketing
  • Advertising Standards Authority (ASA) — can investigate complaints about financial ads
  • Prudential Regulation Authority (PRA) — for certain banking and insurance matters

The FCA’s rules are particularly important because they have statutory force — breaching them isn’t just an advertising standards issue, it’s a regulatory offence.

What counts as a financial promotion?

Any communication that invites or induces someone to engage in financial activity. This includes:

  • Advertisements for loans, mortgages, credit cards
  • Investment product marketing
  • Insurance promotions
  • Pension communications
  • Crypto and digital asset promotions (from October 2023)

Core requirements

All financial promotions must be:

Fair, clear and not misleading

This is the FCA’s overriding principle. Every financial promotion must satisfy this test. Content that’s technically accurate but creates a misleading impression still fails.

Balanced

Benefits and risks must be given equal prominence. You can’t emphasise returns while downplaying risks, or use large type for benefits and small print for warnings.

Targeted appropriately

The content should be appropriate for its likely audience. A promotion aimed at sophisticated investors has different requirements than one targeting retail consumers.

Capable of substantiation

All claims must be backed by evidence. Performance figures, comparisons and statistics need supporting data.

The “clear, fair and not misleading” test

Before finalising any financial copy, ask: would a typical reader understand the key risks? Could they make an informed decision based on this? If not, the copy fails the test.

Risk warnings and disclaimers

Many financial products require specific risk warnings. These aren’t optional marketing choices — they’re legal requirements.

Investments

“The value of investments can fall as well as rise. You may get back less than you invest.” This or similar wording is required for most investment promotions.

Loans and credit

APR must be displayed prominently. For mortgages, “Your home may be repossessed if you do not keep up repayments on your mortgage.”

Pensions

Warnings about the long-term nature of pensions and the impact of charges on growth.

Cryptocurrency

“Don’t invest unless you’re prepared to lose all the money you invest.” Plus warnings that crypto is unregulated and that you won’t have FCA protection.

Presentation rules

  • Risk warnings must be prominent, not hidden in footnotes
  • Font size should be comparable to benefit statements
  • Position should allow them to be seen, not scrolled past
  • Colour contrast must make them readable

Representative examples

When advertising credit products (loans, credit cards, mortgages), you must include a “representative example” showing:

  • Representative APR
  • Typical loan amount
  • Duration
  • Total amount repayable
  • Monthly repayment amount

Representative examples must be up to date and based on current rates. The representative APR must reflect what at least 51% of customers would actually receive. You can’t advertise a rate that only the best-qualified applicants might get.

Example format:

Representative example: Borrow £10,000 over 36 months at 9.9% APR representative. Monthly repayments of £322.67. Total amount repayable £11,616.12.

Representative examples required

Any of these “triggers” require a representative example: APR, interest rate, amount of credit, repayment amount, duration, or any statement suggesting credit is available.

Testimonials and past performance

Using testimonials or performance data in financial promotions has strict rules:

Testimonials

  • Must be genuine and representative
  • Can’t imply typical results without evidence
  • Must include appropriate risk warnings
  • Should be dated to show when they were given

Past performance

  • Must not be used to imply future results
  • Must include “past performance is not a reliable indicator of future results”
  • Should show relevant time periods, not cherry-picked good periods
  • Must be presented fairly alongside relevant context

The approval process

Financial promotions must usually be approved by an authorised person before publication. This affects how you work with financial services clients:

Who approves?

The client’s compliance team or an external compliance consultant. They’re responsible for ensuring promotions meet FCA requirements.

Your role

  • Understand the requirements so your drafts are closer to compliant
  • Build in time for compliance review — it’s not negotiable
  • Don’t push back on compliance changes unless you have a strong basis
  • Ask for guidance early on what claims can and can’t be made

Get it in writing

Always get written sign-off on financial copy. If a client approves something that later proves non-compliant, you need a paper trail showing they took responsibility.

Your liability

The FCA can take action against anyone involved in creating or approving a misleading financial promotion, including copywriters. Take compliance seriously.

Practical tips

Working successfully in financial services copywriting:

  • Learn the language — understand what “capital at risk” means, what APR is, how compound interest works
  • Get briefed on compliance — ask clients for their compliance guidelines upfront
  • Review competitors — see how established firms present similar products (but don’t assume they’re compliant)
  • Question claims — if a client wants to say “best rates” or “guaranteed returns,” request evidence
  • Build in time — compliance review typically adds 1-2 weeks to financial projects
  • Keep records — document approvals and changes for your protection

Summary

Financial services copywriting requires understanding regulatory requirements, not just marketing principles. The stakes are higher because non-compliant promotions can result in FCA action, fines, and reputational damage.

Your job is to create compelling copy that works within these constraints. That means understanding the rules, working closely with compliance teams, and pushing back when clients want to cut corners.