Most businesses assume financial promotion rules are something that happens to the big, formal stuff, the terms and conditions, the key facts document, the small print at the bottom of an advert. I’d gently correct that assumption for any financial services client. The FCA is explicit that its rules apply regardless of media type, a blog post, a tweet, a Facebook update or a line on your homepage counts every bit as much as a printed brochure (FCA, Regulating Financial Promotions and Adverts). If a piece of content promotes a loan, an investment, a mortgage, an insurance product or consumer credit, it’s a financial promotion in the FCA’s eyes, whatever it looks like and wherever it sits.
The rule that never really changes
Underneath a genuinely complicated rulebook sits one deceptively simple standard: every financial promotion must be clear, fair and not misleading. It’s worth knowing that even as the FCA simplifies large parts of its consumer credit promotion rules this year, this particular principle is one it’s explicitly chosen to keep, precisely because it gives consumers a direct legal right to complain if a firm gets it wrong, a protection that doesn’t exist in quite the same way under the newer, broader Consumer Duty (FCA, CP26/15, 2026).
If you take one thing from this piece, it’s that “clear, fair and not misleading” isn’t a compliance checkbox; it’s the actual working standard your copy gets judged against.
The Consumer Duty raised the bar, not just the paperwork
Since 2023, the Consumer Duty has added something genuinely relevant to how content should be written, not just what it must legally include. It requires that communications actually support customer understanding, not merely that they’re technically accurate. That’s a meaningfully higher standard for a copywriter to write to. A promotion can tick every regulatory box and still fail if an ordinary customer would come away confused about what they’re agreeing to. In practice, that means jargon-heavy copy that’s technically correct but practically impenetrable is now more of a genuine compliance risk than it used to be, not just a readability problem.
The risk warning insight I found genuinely useful
Here’s something that changed how I approach financial copywriting, and it comes straight from the FCA’s own research. Firms have long treated risk warnings, “your capital is at risk” and similar phrases, as boilerplate to bolt onto the end of a promotion. The FCA’s own behavioural testing found that consumers frequently don’t actually read those generic bolted-on statements at all (FCA, Risk Warnings for Mainstream Investments, 2026). Their guidance now actively encourages firms to weave risk information into the body of a promotion as part of a genuinely balanced explanation of benefits and risks together, rather than isolating it in a disclaimer nobody reads. For a copywriter, that’s a real shift, risk communication isn’t a legal afterthought tacked on at the end, it’s something that ideally belongs inside the actual narrative of the piece.
I’d argue as well that an informed consumer, making an informed choice, is less likely to create customer service and reputational headaches down the line. It’s worth balancing the risk of losing a sale from overly scary text against the later damage to the company from disgruntled customers leaving comments and reviews all over social media.
Comparisons need to earn their place
One further nuance worth knowing if you ever write comparative content for a financial services client, “we offer better rates than X” style copy. The FCA requires that any comparison be meaningful and presented fairly and in a balanced way, not simply favourable-looking cherry-picking (FCA Handbook, COBS 4). That doesn’t mean you can’t make a comparative case, it means the comparison has to be built honestly enough to survive scrutiny, which is a different discipline to consumer marketing comparisons in most other sectors.
What I’d actually advise
None of this is a reason to avoid writing engaging, human copy for financial services clients, if anything, the Consumer Duty’s focus on genuine understanding rewards clearer, more accessible writing over dense, hedge-everything legal language. What it does mean is that “we’ll get compliance to check it before it goes live” needs to happen for genuinely everything that promotes a product, including the casual social post you didn’t think twice about, not just the formal collateral. The businesses that get caught out tend to be the ones that never questioned whether a piece of content counted as a financial promotion in the first place.
Rich Jarrott is the founder of ZenithSpark and has written for multiple clients in the regulated financial space. To take advantage of his insight visit our contact page.
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