The Financial Conduct Authority (“FCA”) has published guidance on financial promotions on social media. The guidance follows a consultation in 2023 and is a response to the FCA’s concern at the growing use of social media and influencers as part of firms’ marketing strategies.

Whilst the guidance does not create any new obligations for FCA-regulated firms, it is a helpful reminder of those that currently apply, complete with user-friendly examples of good (and bad) practice. For example, it contains information about the requisite level of detail and prominence of any promotion in order to support consumer understanding (particularly in light of the recent introduction of the Consumer Duty). It also encourages firms to consider whether social media is an appropriate medium in the first place to promote certain financial products and services, drawing particular attention to whether “the promotion of debt solutions on social media is compatible with prioritising good outcomes for consumers”.

The guidance also includes in-depth information about how to display risk warnings clearly and prominently, providing tailored advice for various social platforms: from stories on Instagram to livestreams on Twitch, to videos on TikTok and YouTube. There is also helpful advice for regulated firms about how to manage relationships with affiliate marketers, including influencers. The FCA expresses concern about the growth of so-called ‘finfluencers’ who have developed a loyal fanbase but are not authorised to provide financial advice, as well as celebrity influencers who are approached by large companies to promote services. The guidance contains a helpful infographic, prepared in partnership with the Advertising Standards Authority, to help influencers decide whether to promote certain financial products. It also reminds them of the risk of committing a criminal offence by promoting financial products or services without the approval of an FCA authorised person. Finally, there is guidance for the social media platforms themselves to ensure that they do not host illegal content, and the FCA commits to “work closely with Ofcom to create a shared understanding” of how platforms’ obligations under the Online Safety Act will “interact with financial promotion legislation”.

The guidance can be read in full here.