The FCA is looking beyond the financial promotion sign-off
A signed approval is only part of the evidence. Examine the claim, the audience and customer understanding before treating a campaign as ready to publish.
An approval record can tell you who signed off an advertisement. It may still tell you very little about why the claim was accepted or whether the intended audience was the audience that saw it.
Those gaps are worth examining before the next campaign goes live.
The FCA has named the weaknesses
In May 2026, the FCA reported findings from its review of section 21 approvers. It identified unsubstantiated claims, promotions intended for professional clients reaching retail investors, and reliance on third-party templates in place of proper checks. Stronger firms considered the Consumer Duty from the outset. The review concerned firms approving promotions for unauthorised businesses; it was not a survey of every firm’s internal marketing approval process. FCA approver review, 27 May 2026.
The practical questions travel beyond that specific population. What evidence supports the statement? Who should receive it? What did the reviewer actually assess?
Our suggested review structure below addresses those questions. It is not a reproduction of an FCA checklist.
Attach the evidence to the claim
A source document somewhere in a shared drive is difficult to evaluate when the reviewer cannot tell which sentence it supports.
For a comparative claim, retain the comparison basis and the point in time it describes. For a performance claim, identify the period, assumptions and relevant limitations. For a statement about protection or guarantees, make clear what is covered and by whom. The relevant product rules determine what is permissible and what else must appear.
Write the review comment against the exact phrase. “Source required for the comparison in the headline” gives the author a specific task. “Needs compliance work” does not.
If the evidence changes, make the affected claims discoverable. A campaign should not continue using a statement merely because an earlier version received approval.
Make distribution part of the approval
A review of the asset and a review of its placement answer different questions. Both belong in the campaign record.
Record the intended audience, the channels and any restrictions attached to the decision. Then identify who will check the live placement. A professional-client label inside the creative is different from a distribution control that restricts access.
The handover to marketing should be explicit about what can change without another review. A new thumbnail, translated caption or shortened video may introduce a different claim or remove context. Agree the triggers in advance so that the launch team can act without guessing.
A useful handover links the approved version to the placement brief and the owner responsible for publication. It should be possible to follow that link in both directions.
A compliant-looking layout does not prove understanding
The FCA’s March 2026 consumer-understanding review asks firms to consider how communications support informed decisions. It covers testing and management information, communications design, accessibility, financial promotions and governance. The examples illustrate existing expectations under the Consumer Duty; they do not create new requirements or require firms to adopt every practice described. FCA consumer-understanding review, 13 March 2026.
A practical way to challenge an asset is to ask what a customer could misunderstand after seeing it. Then choose evidence that can answer that question. Depending on the communication and its risks, that could include targeted testing, support conversations, complaints or feedback from distribution teams.
Do not confuse engagement with understanding. A click can tell you that a headline attracted attention. It cannot, on its own, establish what the person understood about the product.
Record the question tested, what was observed and what changed as a result. If a warning is repeatedly missed, the response should address its presentation rather than simply recording that the required words were present.
Build a record someone else can follow
Before closing a review, ask a colleague who was not involved to reconstruct the decision. They should be able to identify the asset version, the evidence behind the material claims, the intended audience, the issues raised and how those issues were resolved.
Where a concern was accepted rather than removed, retain the reasoning and the person responsible. Where the creative changed, link the revision to the original finding. A PDF export should preserve those connections, not reduce the review to an approval stamp.
Connor Financial Promotions keeps the creative, findings, comments and approval history together, with PDF exports. The useful record is the one that explains the decision after the original reviewers have left the room.
