The FCA’s social media guidance reflects evolving digital communication practices and regulatory expectations, helping firms manage financial promotions across social platforms, affiliates and digital channels. Many firms reviewing FCA social media regulatory changes are reassessing their financial promotions frameworks, affiliate oversight and digital approval processes.
This article summarises the key themes within the FCA’s social media guidance and what firms should consider when reviewing their financial promotions framework.
Need support reviewing your financial promotions framework? C&G can help with policy updates, training, approval processes and social media compliance reviews. Contact our team today.
Key FCA Social Media Guidance Requirements
The latest FCA social media regulatory changes focus on risk warning prominence, Consumer Duty considerations, affiliate oversight and digital communications.. Key clarifications cover prominence of risk warnings, unintended audiences under the Consumer Duty, and the role of affiliates and influencers. Firms must now assess their financial promotions framework, especially around digital content, affiliate oversight, and platform suitability.
Need help aligning your promotions with the new rules?
C&G can support you with policy updates, training, and framework reviews. Get in touch today.
Key Themes Within FCA Social Media Guidance
The FCA’s social media guidance focuses on several key areas that firms should consider when reviewing digital promotions. These include applying Consumer Duty requirements to social media activity, ensuring the prominence of risk warnings, managing affiliate and influencer relationships, and assessing how platform functionality may affect customer outcomes. The guidance also highlights the importance of considering audience reach, suitability, and the potential risks associated with digital communications across different channels.
Key Areas Covered by FCA Social Media Guidance
The final guidance has minor amendments but remains largely unchanged from the draft guidance. Amendments are summarised below:
Prominence: The guidance emphasises that where information is required to be prominently displayed, it should not be hidden or cut off due to design, and if that is not possible, it should be included in an image. Risk warnings should stand out but do not necessarily need to be as large as the headline.
Consumer Duty: Firms should consider if their ads might reach unintended audiences on social media, leading to harm or non-compliance. Using social media tools to target ads may be inappropriate where the tools are incapable of excluding targets in a negative target market.
Affiliate Marketing: If an approved promotion is changed by an unauthorised entity, the person who approved it is not necessarily responsible. However, firms should reconsider their relationship with affiliates if there is concern about unauthorised changes. Affiliates are also given guidance on understanding whether they are involved in regulated activities.
Shared Social Media Profiles: Changes clarify when promotions from unregulated overseas entities or shared profiles could affect UK consumers and fall under UK financial promotion rules. The test for whether the financial promotion restriction applies is whether the promotion is capable of having an effect in the UK.
FCA and Social Media: Influencers, Marketing and Ongoing Oversight
Social media marketing can create additional regulatory challenges for firms, particularly where third parties are involved in promoting products or services. Under FCA expectations, firms remain responsible for ensuring that financial promotions are clear, fair and not misleading, even when content is distributed through affiliates, introducers or influencers.
When working with influencers or ‘finfluencers’, firms should consider:
- Whether promotions remain accurate when shared, edited or repurposed across channels
- How risk warnings will appear on different social platforms and formats
- Whether audience targeting aligns with Consumer Duty expectations
- How affiliate marketing activity will be monitored and recorded
- Whether approval and sign-off processes extend to third-party content
Firms should also review whether social media marketing is appropriate for the product or service being promoted. Complex products, higher-risk offerings and communications aimed at broad audiences may require additional controls, monitoring and governance.
Effective oversight helps firms reduce compliance risk while maintaining consistent customer outcomes across digital channels.
Financial Promotions Framework Checklist for Firms
Firms should promptly benchmark their existing financial promotions framework against FCA social media guidance. Consider the following actions:
- Update financial promotions policies and procedures for robust approval and monitoring.
- Explicitly consider Principle 12 in ongoing approval processes to ensure good customer outcomes.
- Maintain thorough records of approved financial promotions, including digital communications.
- Share this guidance with affiliates, including introducers and ‘finfluencers’, promoting the firm’s services.
- Monitor affiliate marketing actions for customer outcome alignment and assess partnership volume for effective monitoring.
- Ensure compliance with financial promotions requirements when working with ‘finfluencers’.
- Clearly differentiate between firms operating in different jurisdictions, especially when directing UK customers to overseas entities.
- Cryptoasset firms should familiarize themselves with relevant regulatory guidelines before promoting on social media.
- Assess social media suitability for each product or service, considering complexity and target market, and ensure compliance with standalone promotion regulations.
How C&G’s services can help
We are well placed to assist firms with their financial promotion approval framework. We offer health checks on existing controls, policy drafting and bespoke training solutions to firms and venues. Contact us with your requirements if you need assistance in this area.
