The UK’s Financial Conduct Authority just put the financial promotions industry on notice. A fresh review found that several authorized firms are falling short when it comes to approving promotions — and the regulator isn’t letting it slide.
The FCA looked at 10 firms authorized to sign off on financial promotions for businesses that don’t hold their own FCA authorization. These are called Section 21 approvers, and their job is basically to act as a gatekeeper — making sure that any promotion reaching UK consumers is fair, clear, and not misleading. Some firms are doing that job well. Others, pretty clearly, aren’t. The review turned up promotions containing unverified claims, materials aimed at professional clients that somehow ended up in front of retail investors, and firms that leaned on third-party templates without running proper checks of their own. That’s a problem, and the FCA said so directly.
Not a minor one, either.
Lucy Castledine, the FCA’s director of consumer investments, put it plainly: consumers run into these promotions every single day, across all kinds of platforms. The stakes are real. A misleading promotion doesn’t just waste someone’s time — it can push them toward a genuinely harmful financial decision. Castledine’s point was that every approved promotion needs to be fair and clear, full stop, no exceptions based on how busy a compliance team is or how convenient a template looks.
What the FCA Actually Found
The review covered promotions approved since each firm received its authorization. That scope matters — the FCA wasn’t just spot-checking recent work, it wanted to see how firms had been behaving since they got the green light to operate as Section 21 approvers. And the picture wasn’t great across the board.
Some firms are applying Consumer Duty properly. They’re checking that promotions are accurate, that the audience is right, that claims can actually be backed up. But others aren’t doing that work. The template problem keeps coming up — firms treating third-party materials as pre-approved rather than running their own independent checks. That’s not how it’s supposed to work. The FCA’s rules are clear that the approving firm carries responsibility for what it signs off on, regardless of where the original content came from.
The sectors under the microscope were Buy Now Pay Later, crowdfunding, and corporate finance. All three are areas where promotional material can get complicated fast, and where the gap between what a promotion implies and what a product actually delivers can be wide. Buy Now Pay Later in particular has drawn regulatory attention across multiple jurisdictions — the consumer risk there is well-documented.
Enforcement Steps Already Taken
One firm has already been required to run a remediation exercise. Access to certain websites has been restricted for retail customers. The FCA didn’t name the firm publicly in the review, so the specifics there are murky, but the action itself is concrete.
And it probably won’t stop there. The FCA was explicit that monitoring is ongoing and that firms not meeting the standards will be held accountable. That’s not vague regulatory language — it’s a signal that more enforcement actions are possible if the review findings don’t translate into better behavior.
The regulatory framework that makes all of this enforceable came into effect on February 7, 2024. Before that date, the rules governing how authorized firms approve promotions for non-authorized businesses were less structured. The 2024 changes tightened that up considerably, setting out clear obligations for Section 21 approvers and giving the FCA sharper tools to act when firms don’t comply.
Why This Matters for Crypto and Alternative Finance
Crowdfunding and Buy Now Pay Later sit right at the edge of where traditional financial regulation meets newer, faster-moving products. Crypto-adjacent platforms and alternative investment services often rely on exactly this kind of third-party approval structure to market legally in the UK. If the approver isn’t doing its job, the entire chain breaks down — and it’s retail investors who bear the cost.
The FCA’s broader push on Consumer Duty has been running for a while now, and the financial promotions review fits squarely into that. Firms are expected to think about outcomes for consumers, not just tick compliance boxes. Approving a promotion because the template looks fine isn’t good enough anymore.
Ten firms reviewed. One remediation already ordered. Retail access to certain sites blocked. The FCA said it’s watching.
Frequently Asked Questions
Which sectors did the FCA’s financial promotions review cover?
The review focused on promotions related to Buy Now Pay Later, crowdfunding, and corporate finance, assessed across 10 firms authorized as Section 21 approvers.
When did the rules for Section 21 approvers come into force?
The regulatory standards governing how authorized firms approve financial promotions for non-FCA authorized businesses took effect on February 7, 2024.