FCA Social Media Financial Promotions: A Guide for Marketing Teams

Social media has become one of the primary channels financial services brands use to reach investors, savers and customers, and it is also one of the areas where the FCA has sharpened its focus. In March 2024, the FCA finalised FG24/1, its guidance on financial promotions on social media. The guidance doesn’t introduce a separate rulebook for social channels. Instead, it confirms that existing financial promotion rules apply regardless of format: content must be fair, clear and not misleading, it must present a balanced view of benefits and risks, and it must support customers in making informed decisions.

For marketing teams, that means the question isn’t “does this feel like an advert?” It’s whether the communication, in substance, invites or encourages someone to engage with a financial product or service. A well-produced video, a quick caption, a meme and a five-second Story can all meet that threshold. This guide walks through what FG24/1 means in practice, where the common risk points sit and how marketing and compliance teams can build social campaigns that are both compliant and genuinely engaging.

What Are the FCA Rules for Social Media Financial Promotions?

FG24/1 is technology-neutral by design. The FCA didn’t write a social-media-specific rulebook; it applied its existing expectations for financial promotions to social channels and explained how those expectations translate to the way people actually use platforms like Instagram, TikTok, LinkedIn and X.

In plain English, a financial promotion is any communication that invites or induces someone to engage in a financial product or service, where that communication is made in the course of business. It doesn’t need to look like a formal advert. It doesn’t need a call to action, a product name or a link. If the effect of the content is to encourage engagement with a regulated product, it’s likely to fall within scope.

The core standard hasn’t changed with FG24/1: promotions must be fair, clear and not misleading. What has changed is the FCA’s willingness to say, directly, that this standard applies just as firmly to a 15-second Reel as it does to a printed brochure. Marketing teams planning social content for regulated products should start from that assumption rather than treating format as a reason to relax the usual scrutiny.

When Does a Social Media Post Become a Financial Promotion?

The FCA describes financial promotions broadly, and it specifically recognises social media as a channel through which they occur. That’s an important starting point, because a lot of informal or short-form content gets produced under the assumption that it sits outside the regime. It often doesn’t.

Content that can constitute a financial promotion includes:

Organic posts and paid social ads, whether they name a specific product or simply promote the brand’s offering
Videos, Reels and Stories, including behind-the-scenes or “day in the life” content that references investment products or services
Memes and other visual formats, which can carry a promotional message even when the tone is light
Influencer and finfluencer content produced on a firm’s behalf or referencing its products
Content posted in private groups, closed communities or invitation-only channels
Reposts, shares and other redistributed content, even when the original poster isn’t the firm itself

The format of a post, its tone or its apparent informality doesn’t remove regulatory responsibility. What matters is the substance and likely effect of the communication.

Organic vs Paid Social Content

It’s tempting to treat “organic” as shorthand for “not really a promotion,” particularly when the content was produced quickly, without a media spend behind it. That distinction doesn’t hold up under FG24/1. The FCA is concerned with the content and purpose of a communication, not the mechanism used to distribute it. A founder’s unscripted LinkedIn post about a fund’s recent performance can be just as much a financial promotion as a paid ad running the same message. Marketing teams should assess organic content against the same standard they’d apply to paid media, rather than assuming a lighter review process is appropriate simply because no budget was attached.

What About Reposts, Shares and Third-Party Content?

Content that travels beyond its originally intended audience carries additional risk. A post approved for a specific context, a particular platform, a specific audience segment, can end up reshared, screenshotted or repurposed somewhere else entirely, often without the caveats, disclaimers or context that made the original version acceptable. Marketing teams should think about this at the point of creation: what happens if this is shared without its caption, cropped, or reposted by someone with a different audience? Where a firm has any influence over how content is redistributed, whether through affiliates, partners or its own employees, that influence should be reflected in briefing and monitoring practices, not treated as an unmanageable risk.

The “Fair, Clear and Not Misleading” Standard

“Fair, clear and not misleading” is the core test underneath every financial promotion, and it’s the standard marketing teams need to translate into working practice, not just cite in a compliance sign-off. In social media terms, it means the creative has to do two jobs simultaneously: it needs to be persuasive enough to work as marketing, and it needs to give the audience enough information to understand what they’re actually being invited to consider.

Balance Benefits With Risks

Creative that leans heavily on the upside of a product- strong returns, ease of access, a compelling brand story- while treating risk as a footnote, is unlikely to meet the standard. The FCA expects a balanced view: benefits and risks presented with comparable weight, so the audience isn’t left with a skewed impression of what the product actually offers. In practice, this often means resisting the instinct to lead entirely with the strongest selling point and building risk information into the substance of the message, not just its small print.

Make Risk Warnings Prominent

Where risk information is legally or regulatorily required, its prominence matters as much as its presence. A risk warning buried at the bottom of a long caption, shown for a fraction of a second in a video, or set in text too small to read on a mobile screen, is unlikely to satisfy the standard even if the words themselves are technically correct. Marketing teams should treat placement, timing, contrast and legibility as compliance decisions, not just design choices. If a risk warning needs a viewer to pause a video or expand a caption to see it, that’s a signal the current format isn’t doing its job.

Consider the Entire Customer Journey

A social post rarely stands alone. It’s usually the first step in a journey that continues through a landing page, an app download or a form. The FCA’s guidance encourages marketers to look at that full journey when assessing whether an audience is genuinely informed, rather than judging each touchpoint in total isolation. That said, this doesn’t lower the bar for the initial post: each individual promotion still needs to satisfy the applicable requirements on its own terms. The practical approach is to map the journey end to end, checking that context and risk information carry through consistently from the first impression to the final decision point.

Can You Rely on a Link for Important Risk Information?

This is one of the most common practical questions social teams raise, and the honest answer is: not automatically. Directing an audience to a landing page, a longer disclosure document or a pinned comment doesn’t, by itself, resolve a compliance gap in the original post. The FCA’s underlying question is whether the consumer receives the information they need to understand the promotion appropriately, at the point where it matters.

That plays out differently across formats:

Static posts and captions: a link can support additional detail, but the post itself still needs to be fair and balanced on its own; it shouldn’t rely on the link to correct a misleading headline claim.
Videos: an on-screen link or “see bio” prompt doesn’t compensate for a spoken claim that overstates benefits or omits a material risk during the video itself.
Stories: given how briefly Stories are visible and how easily a swipe-up or link sticker gets missed, teams should be cautious about treating a linked page as the sole source of required risk information.
Landing pages: once someone does click through, the landing page needs to carry the detail promised, consistently with what the social post implied, not a different or diluted message.

The safer approach is to build enough balance and context into the promotion itself, and treat linked pages as reinforcement rather than a substitute for compliance.

FCA Rules for Influencers and Finfluencers on Social Media

FG24/1 gives specific attention to influencers and “finfluencers,” and the warning is a serious one: an unauthorised person promoting regulated financial products or services, without the approval required under the relevant rules, may commit a criminal offence. This isn’t a theoretical risk confined to influencers acting alone; it has direct implications for any firm working with creators.

Who Is Responsible for Influencer Content?

Handing a creator a product brief and a fee doesn’t transfer compliance responsibility to them. Authorised firms remain responsible for ensuring that promotional content produced on their behalf, including content created and posted by an influencer, meets financial promotion requirements. Marketing teams that treat influencer partnerships as a channel outside their usual compliance process are taking on risks they may not have accounted for. The influencer relationship needs the same rigour as any other marketing channel producing regulated content, arguably more, given the speed and informality of social platforms.

Approval, Briefing and Monitoring

Good practice starts before a single piece of content is filmed. Clear briefs, defined boundaries on what can and can’t be said, and a pre-publication approval step where appropriate all reduce the risk of a creator introducing an unapproved claim, in their own words, that the firm then becomes responsible for. Monitoring shouldn’t stop once content goes live either. Comments sections, follow-up posts and reposted clips can all extend or distort the original message.

What Marketing Teams Should Tell Influencers

A working influencer brief for regulated content should cover:

Which claims and messages are approved for use, in what wording
Required risk warnings and disclosures, including where and how prominently they need to appear
Statements or claims that are prohibited or haven’t been approved
The requirement for content to be reviewed and approved before it’s published
Restrictions on editing approved copy once it’s been signed off
Expectations around reposting, repurposing or extending the content beyond its original use

Treating this as a written, referenced checklist rather than a verbal understanding reduces ambiguity and gives the firm a record to point to if content is later questioned.

Choosing the Right Social Platform for a Financial Promotion

Not every platform format gives a marketing team enough space or functionality to communicate a promotion compliantly. The FCA has raised concerns specifically about formats like Instagram Stories, where limited screen time and minimal text space may not be sufficient to convey the balance and risk information a promotion requires. Choosing a format is, in effect, a compliance decision as much as a creative one.

Short-Form Video and Reels

Fast-cut, high-energy formats are effective at capturing attention, but they compress the time available to deliver a balanced message. Visual risk warnings need to stay on screen long enough to be read, spoken claims need to match what’s approved, and audio-only disclosures are easy to miss if a viewer is watching without sound. Teams should ask whether the required information can realistically be absorbed within the video’s runtime, not just whether it technically appears somewhere in the frame.

Stories and Temporary Content

Stories present a particular challenge: content disappears after a short window, viewers move through them quickly, and there’s limited space for context. Beyond the visibility question, firms also need a way to retain records of what was published and when, since ephemeral content doesn’t leave the same trail as a permanent post. If a format’s brevity makes it difficult to include required information prominently, that’s a reason to reconsider the format, not to reduce the information.

Static Posts and Paid Social Ads

Static formats generally offer more room to work with, but creative hierarchy still matters. If the headline claim, imagery and call to action dominate the design while the risk warning is small, low-contrast or positioned as an afterthought, the post is unlikely to meet the fair and balanced standard. Paid social ads carry an added consistency requirement: the message in the ad needs to match what a user finds when they click through, rather than setting an expectation the landing page doesn’t support.

Approval, Governance and Record-Keeping for Social Campaigns

Individual post-level checks matter, but they work best inside a wider governance process. Compliance built into a campaign from the planning stage catches problems while they’re still cheap to fix; compliance added as a final check before publishing tends to catch them too late, when the creative, media plan and timeline are already locked in.

A workable governance process for social campaigns should address:

Who has authority to sign off promotions before they go live, and at what stage in the process
Version control, so the team always knows which version of a piece of creative was actually approved
A clear record of approved copy and creative, kept separately from working drafts
A defined process for handling changes made after approval, however minor they seem
Campaign records that can be retrieved if a promotion is later questioned
A process for monitoring content once it’s live, not just at the point of publishing
Oversight of influencer and affiliate content, consistent with the approval and briefing practices above

Marketing teams should also understand, at a working level, the concept of the financial promotions approval gateway: a regime intended to ensure that only firms with appropriate permission can approve financial promotions for unauthorised persons, such as some influencers. This isn’t a general licence for any FCA-authorised firm to approve third-party content; specific permission is required. Marketing teams working with unauthorised creators or affiliates should treat this as a question for their compliance function to confirm, rather than an assumption to make internally.

A Pre-Publish FCA Social Media Compliance Checklist

Before a piece of social content goes live, run it through the following:

Could this communication constitute a financial promotion, regardless of its format or tone?
Has the intended and foreseeable audience been considered, including who might see or reshare it beyond the original target?
Are the claims made fair, clear and not misleading?
Are benefits and risks presented in a balanced way?
Is required risk information sufficiently prominent, in placement, timing and legibility?
Can the chosen platform and format actually communicate the message appropriately, given its space and time constraints?
If influencer or affiliate content is involved, are the required controls and approvals in place?
Does the final creative match the version that was actually approved?
Have appropriate records been retained, covering the approved content, its approval and its publication?
Is there a process in place to monitor the campaign once it’s live?

A single “no” on this list is a reason to pause before publishing, not a reason to note it and move on.

How Marketing and Compliance Teams Can Work Better Together

Compliance is often framed as a constraint on creative marketing, something that slows a campaign down or waters down the message. That framing tends to produce exactly the friction it’s trying to avoid. When compliance is involved from the planning stage, rather than brought in at the final review, it’s possible to establish guardrails early enough that the resulting creative is both engaging and ready to withstand regulatory scrutiny.

Practically, this looks like:

Compliance input during campaign planning, not just final sign-off, so risk considerations shape the creative brief from the start
Pre-approved messaging frameworks that give marketers language they know is compliant, reducing back-and-forth on every new piece of content
Creative templates and guardrails that build required elements, such as risk warning placement, into the design system itself
Approval workflows built for the pace of social media, rather than processes designed around slower, traditional media
Consumer testing that checks whether real audiences understand a message the way it’s intended, not just whether it’s technically compliant
Monitoring after launch, so issues are caught while a campaign is still running
A feedback loop from rejected or heavily amended creative, so the same issues don’t recur campaign after campaign

This is the space Hub Agency works in directly. Our Specialist Compliance Support, including Consumer Duty testing and pre-approval reviews, is delivered alongside a client’s in-house marketing and compliance teams rather than as a separate, bolted-on step. The aim is to help both functions move faster together, not to add another layer of process. For how this looks at the level of a full marketing strategy rather than a single channel, see our guides to asset management marketing strategy and fintech marketing agency vs in-house team.

Build Compliant Social Campaigns Without Losing Creative Impact

FCA compliance and strong creative marketing aren’t competing objectives. Treating them as opposites usually produces the worst of both outcomes: creativity that gets diluted by late-stage compliance edits, or compliance processes that get bypassed under deadline pressure. The firms that get the most out of social media are the ones that build compliance into the creative process from the start, so the two reinforce each other rather than pulling in different directions.

That’s the position Hub Agency works from: bold enough to convert, compliant enough to approve. We work with asset managers, investment trusts, wealth managers and fintechs to translate complex, regulated propositions into social content that’s genuinely engaging, while accounting properly for FCA requirements at every stage.

If your team is reviewing its social media approach in light of FG24/1, or you want a second opinion on where your current process might be exposed, get in touch with Hub Agency to talk through your specific campaigns and workflow.