The FCA Financial Promotion Approval Workflow, Step by Step

This is the page the usual guidance does not have: the actual UK financial-promotion approval workflow, step by step. It sits within the wider system mapped in our guide to content marketing in regulated industries, and it is deliberately concrete, because the value is in the detail.

One thing to be clear about before any of the steps. This explains how the regime works so you can understand and design around it. It does not tell you whether a given piece of your content is a financial promotion, or which exemption you can rely on, because those determinations depend on your specific facts and are regulated judgements. Ridley Digital is not an authorised section 21 approver or a law firm. For your own content, those calls belong with a qualified approver or legal counsel.

Step 0: is it even a financial promotion?

Everything starts here, because the regime only bites if the content is a financial promotion in the first place. The test, set out in PERG 8 and rooted in section 21 of FSMA, is whether the communication is an invitation or inducement to engage in investment activity, communicated in the course of business. Those words do a lot of work. An invitation or inducement is content designed to lead someone toward a financial action, not merely neutral information. In the course of business captures essentially all marketing.

The threshold catches far more content than marketers expect. It is not limited to adverts. Websites, emails, social posts, landing pages and app content can all be financial promotions if they invite or induce investment activity. The FCA’s guidance is clear that the restriction covers all media formats. The practical consequence is that you cannot assume a piece is outside the regime because it does not look like a traditional advert; the test is about what the content does, not what format it takes. Whether any specific piece meets the test is exactly the kind of judgement to take advice on.

Step 1: who is allowed to approve it

If the content is a promotion and you are not communicating it as an authorised person yourself, it has to be approved by an authorised person, and since 7 February 2024 that is not something any authorised firm can simply do. A firm needs specific FCA permission to approve financial promotions for unauthorised firms, the section 21 approver gateway. Firms applying for that permission are assessed for competence and expertise, and the FCA expects the approval scope to match the firm’s actual area of expertise rather than being a general licence to approve anything.

There are exemptions where the gateway permission is not required. An authorised firm can approve a promotion prepared by its own appointed representative for the activities the firm has accepted responsibility for, and an authorised firm can approve a promotion from an unauthorised entity within the same corporate group. The Financial Promotion Order contains a range of other exemptions, for example around communications to certified high-net-worth or sophisticated investors. These are stated here so you know such routes exist; which, if any, applies to your situation is a regulated judgement, not something to infer from a general guide.

Step 2: the standard the approver applies

Once the right person is approving, they apply a defined standard: the promotion has to be clear, fair and not misleading. In practice that breaks into several checks. Claims have to be substantiated before approval, not defended later; the FCA’s 2026 approver review criticised firms that approved adverts carrying unsubstantiated claims. Risk and return have to be balanced, so benefits are not amplified while risks are buried. And the audience has to be right: promotions intended for professional clients must not be served to retail investors, a control the same 2026 review found weaker firms had failed.

One specific trap the FCA named is worth pulling out, because it is common and tempting. Relying on a third-party template is not a substitute for the firm’s own checks. A template can look professional and be widely used, but the approving firm carries responsibility for what it signs off regardless of where the content originated, so treating a template as effectively pre-approved is exactly the failure the regulator punished. The standard is applied by the approver to this content, for this audience, every time.

Step 3: approval is recorded, then monitored

Approval is a moment, but the obligation is continuous, which is the part teams most often miss. The approval itself has to be evidenced, and beyond that, section 21 approvers carry ongoing monitoring duties and report to the FCA on a six-monthly basis. A promotion that has been approved but later drifts out of compliance, because the product changed, the market moved, or a claim that was fair has aged badly, has to be caught, and its approval reconsidered or withdrawn. The FCA has highlighted, as good practice, firms that use software to monitor approved promotions on clients’ websites and flag changes for investigation.

The recordkeeping side of this, what the evidence has to contain and how it has to be captured and retained, is substantial enough to be its own subject, covered in our guide to the compliance evidence trail. The point to hold here is that an approval you cannot evidence, and a monitoring duty you are not discharging, are both failures even if the content was compliant when it went live.

Step 4: when content changes or the rules change

Approval is a point-in-time status, not a permanent clearance, so it is worth knowing what re-triggers it. A material change to the content is the obvious one: edit the substance of a promotion and the approved version is no longer what is live. A change in the underlying product can do it too, because a promotion that was accurate for the old product may mislead for the new one. And a change in the rules themselves can pull a previously compliant promotion out of line. The discipline is to treat approval as attached to a specific version of specific content under specific rules, so that when any of those moves, the approval is revisited rather than assumed to carry over.

The cross-border note

One caution if you operate in more than one jurisdiction. A UK financial promotion and a US one run on entirely different regimes, with different tests, different approvers and different records. Clearing content under the UK section 21 process does nothing for your US obligations, and vice versa. If you market in both, you run both workflows in parallel rather than treating one as covering the other. The US equivalent, the broker-dealer sign-off model, is set out in our guide to the FINRA Rule 2210 sign-off model.

FAQs

What is a financial promotion under FCA rules?

A financial promotion is a communication that is an invitation or inducement to engage in investment activity, made in the course of business, as set out in section 21 of FSMA and explained in PERG 8. The definition is broad and catches far more than traditional adverts: websites, emails, social posts, landing pages and app content can all qualify if they invite or induce investment activity. Whether a specific piece of your content meets the test is a regulated judgement that depends on the facts, so it is one to take advice on rather than assume.

Who can approve a financial promotion?

An authorised person communicating their own promotion does not breach the restriction, and otherwise a promotion for an unauthorised firm has to be approved by an authorised person who holds the specific approver permission. Since 7 February 2024, that permission is a dedicated gateway, and the FCA expects the approval scope to match the firm’s area of expertise. Some exemptions remove the permission requirement, such as a firm approving its own appointed representative’s promotion or a promotion from within the same corporate group. Which route applies to a given situation depends on the facts.

What is the s21 gateway?

The section 21 gateway is the permission regime, in force since 7 February 2024, under which an authorised firm must hold specific FCA permission before it can approve financial promotions for unauthorised firms. Firms are assessed for competence and expertise when they apply, and the FCA expects them to approve only within their area of expertise rather than treating the permission as a general licence. The gateway exists to make sure that the firm acting as gatekeeper for promotions reaching consumers is genuinely equipped to do that job.

Does financial promotion approval expire?

Approval is a point-in-time status rather than a permanent clearance, so while it does not “expire” on a fixed date, it can stop being valid. A material change to the content, a change in the underlying product, or a change in the rules can all mean the approved version no longer matches what is live, which calls for re-approval. Approvers also carry ongoing monitoring duties, so a promotion that drifts out of compliance after going live has to be caught and its approval reconsidered. Treat approval as attached to a specific version under specific rules.

Can you use a third-party template for approval?

A template can speed production, but it is not a substitute for the firm’s own checks, and treating it as one is a failure the FCA specifically named in its 2026 approver review. A template may look professional and be widely used, but the approving firm carries responsibility for what it signs off regardless of where the content came from. So the standard still has to be applied to the actual content, for the actual audience, every time. Templates can encode good practice, but they cannot replace the approval itself.

Last reviewed: June 2026

This article is general information about the UK financial-promotion regime and is not legal, compliance or regulatory advice. Ridley Digital is not an authorised section 21 approver or a law firm. Whether a communication is a financial promotion, and which exemption or approval route applies, depends on the facts; take advice from a qualified approver or lawyer before relying on this.