Financial promotions approval process: a template built on FCA rules

What the rules require of an approval process

No FCA rule sets out a sign-off workflow for a firm's own promotions. The FCA's guidance is that its systems and controls rules require firms that communicate or approve financial promotions to have systems and controls, or policies and procedures, for complying with them (COBS 4.10.1G); SYSC 6.1.1R, for example, requires “adequate policies and procedures sufficient to ensure compliance”. Other provisions fix what those procedures must deliver:

This page covers a firm's own promotions. Approving promotions for unauthorised businesses adds the duties in section 21 approval and the gateway; the content checks are in the financial promotions checklist.

The stages, from brief to withdrawal

Each stage names who does it. The rules cited set the minimum; the structure around them is our suggestion.

1. Brief, by the requesterProduct, audience, markets, channels, run dates and message, agreed before drafting starts. The products and markets decide which rules apply.
2. Draft with evidence, by the authorEvery claim and figure linked to its source, with any prescribed warning for the product. Submitted as customers will see it: final artwork, the video with sound, the page on a phone.
3. First-line check, by a trained reviewerIs it complete, and does the evidence support each claim? If not, it goes back to the author before it reaches compliance.
4. Compliance review, by the compliance approverConfirms the promotion complies on each channel it will run on, recording each issue against the words it concerns. Tests customer understanding where the Consumer Duty makes that appropriate (PRIN 2A.5.10R).
5. Senior sign-off, for high-risk promotionsCertification by the compliance oversight function is required for a promotion of a non-mass market investment (COBS 4.11.4R) or a contingent convertible instrument (COBS 22.3.5R) likely to reach retail clients. Elsewhere your policy decides, for example for CFDs, cryptoassets or a first campaign in a new market.
6. Decision and record, by the approverThe decision, any conditions, the reasons it complies, the date, the review date and the exact version approved (COBS 4.11.1R; COBS 4.11.2G).
7. Publish, by the distribution ownerOnly the approved version goes live. Each placement is checked against it, captured with the date and added to the distribution list.
8. Monitor, by the requester and complianceComplaints, customer questions, drop-off points and affiliates' copies (PRIN 2A.9.8R). Any trigger listed below sends it back to compliance review.
9. Withdraw, by the requester and the distribution ownerEvery placement taken down, everyone using it told, the date recorded, and the record kept for its retention period (COBS 4.10.8G; COBS 4.11.1R(3)).

Who does what, and the expertise they need

Whoever signs off needs expertise in the product, not only in the rules:

A firm must not communicate or approve a financial promotion unless the individual or individuals responsible for the compliance of the financial promotion with the financial promotion rules has or have appropriate competence and expertise.

That means expertise in “the investment or financial service to which the financial promotion relates” (COBS 4.10.9AR(2)). The rule covers investment promotions under COBS 4; for others, such as consumer credit, the general competent employees rule applies (SYSC 5.1.1R; SYSC 3.1.6R for firms subject to SYSC 3).

Record, for each promotion, how you satisfied yourself of that expertise (COBS 4.11.1R(2B)); a competence file for each approver, referenced in each record, is one way to do this. The FCA's guidance lists what to weigh: resources and controls for approving and monitoring, experience or qualifications in the products, and the employment history and qualifications of those who approve (PS23/13, Annex 3, paragraph 49). It would generally expect a firm promoting investments covered by its own Part 4A permission to have met the requirement through its regulated business, but asks for particular care with new or innovative products (paragraph 52).

What to record for each promotion

COBS 4.11.1R requires “an adequate record” of each promotion a firm communicates or approves, other than one made in a personal visit, telephone conversation or other interactive dialogue. Image advertising and non-retail communications are outside it. It lists no fields; these let you show later that each requirement was met:

Keep the record in your own systems. Social media platforms “may refresh content from time to time, deleting older material” (FG24/1, paragraph 3.16).

How long to keep the record

COBS 4.11.1R does not say when its periods start. Counting from the date the promotion was last communicated, as MCOB 3A.9.1R does, is the cautious reading. Where more than one period applies, keep the longest.

Turnaround, escalation and review dates

The FCA sets no turnaround times, and no general review interval for a firm's own promotions. Those below are our suggestions; only the provisions cited are requirements.

A template approves wording and layout, not the figures dropped into it; each use is still checked against its conditions.

Escalation, written down before it is needed:

• A missed target goes to the head of compliance the same day.
• A disagreement between author and approver goes to the senior sign-off holder, whose decision and reasons go on the record.
• Nothing goes live while a decision is pending.

Set a review or expiry date at approval: the end of the campaign, or at most 12 months for evergreen pages, brought forward to the next scheduled change in any figure the promotion quotes. A CFD loss percentage, for example, must be recalculated every three months (COBS 22.5.6R(4)).

When a live promotion goes back for review or comes down

An approval covers the version approved, on the facts of the day it was given. Each of these sends a promotion back to compliance review:

If a firm continues to communicate a financial promotion when the financial promotion no longer complies with the rules in this chapter, it will breach those rules.

Withdrawing means taking down every listed placement, pausing paid campaigns, telling affiliates to remove their copies, and recording the date, the reason and evidence that each has gone. A firm that approved a promotion for someone else must also withdraw its approval and notify anyone it knows to be relying on it “as soon as reasonably practicable” (COBS 4.10.2R(2); similarly ICOBS 2.2.3R and CMCOB 3.2.1R(3)). A firm that finds another firm's communication in its distribution chain is not delivering good outcomes for retail customers must “promptly notify the issue” to the relevant firm (PRIN 2A.5.14R).

What changes for social posts, video, websites and affiliates

The sign-off and record-keeping provisions apply to digital media “in the same way as to print, broadcast and outdoor media” (FG24/1, paragraph 3.17). What changes by channel is what the approver has to look at.

There is more on each channel in financial promotions on social media and affiliate marketing compliance.

What the FCA has found in approval processes

In February 2024 the FCA fined a former director of London Capital & Finance plc, who was responsible for compliance, £31,800 and banned him from working in financial services. He “recklessly signed off hundreds of financial promotions”, “failed to obtain evidence of the claims being made” and “continued to approve promotions even when he became aware of inaccurate claims”. The FCA said that under him “the approval process became an ineffective tick-box exercise” (FCA, 13 February 2024).

In May 2026, the FCA's review of 10 firms that approve promotions for unauthorised businesses found some passing unsubstantiated claims, letting retail investors see promotions meant for professional clients, and relying on third-party templates instead of their own checks (FCA, 27 May 2026).

The FCA's March 2026 review of consumer understanding drew on a September 2025 survey of 38 firms across insurance, retail banking, payments, consumer finance and CFDs (FCA, 13 March 2026). Its examples “do not create new regulatory requirements”, but they show what the FCA compares an approval process with:

✓ Good practice

• “One firm used readability checks, approved templates, rules for keeping risks prominent, and a documented sign-off process to stay consistent across all channels.”
• At a small firm, “A straightforward approval process, supported by short checklists and clear signoff, meant decisions were recorded consistently without needing complex systems.”

✕ Areas for improvement

• “Many firms relied only on compliance checks or sales data, without checking that customers understood the promotion.”
• “Some firms approved promotions without monitoring understanding, drop-off points or complaints.”
• “Some firms do not have a clear picture of who is responsible for decisions, or how those decisions are made.”

What to report to the board

Under the Consumer Duty, the governing body must review and approve, at least annually, a report “setting out the results of its monitoring” of customer outcomes (PRIN 2A.8.3R and 2A.8.4R), including outcomes from its communications (PRIN 2A.9.8R). The FCA suggests governance committees receive “comprehension driven KPIs, not just compliance, sentiment or activity metrics”, and warns that overall data “can hide differences in how well different groups understand the information” (FCA, 13 March 2026).

Measures we suggest:

A checklist for the final sign-off

Connor takes each promotion from submission to approval, with every version on record and comments on the creative and on each finding. It works out which rules apply from the firm's home regulator, its markets and its products, and lists each problem with the rule it breaks and the fix. A person at the firm makes the decision. The record holds every version, the rules as they stood that day and who decided what, and Connor reports on turnaround, approval rates and common issues.