The FCA read the minutes , and found the marketing had outrun the meeting
Two FCA publications, three days apart, describe the same animal from opposite ends. Between them sits the sign-off queue every growing fintech pretends is somebody else's problem.
What the regulator actually did in one week#
A fox counts the gates before it counts the geese. Two of them opened this week, three days apart, and read together they describe exactly where the regulator now expects a growing firm to be spending its attention.
On 7 August the FCA said in a formal statement that We have also sent an information request to around 900 Annex 1 firms. Annex 1 firms are the unregulated lenders, safe custody providers, money brokers and financial leasing companies that register with the FCA for anti-money-laundering purposes. Having worked with 300 of them in late 2025, the regulator has now reached the rest of the population.
The consequence is stated on the same page without softening: Firms should expect registration applications to take longer. That is repeated on the operational page a founder actually uses, where the FCA warns that Annex 1 lending firms should expect it to take longer than usual.
Then, three days later, the other end of the telescope#
On 10 August the FCA published good and poor practice from its Early and High Growth Oversight pilot. Between July 2025 and March 2026 it engaged with 15 firms across asset management, wealth management and payments, and its central finding is a single sentence any scaling business should read twice: In some firms, governance arrangements had not kept pace with business growth.
The same day it widened its Scale-up Unit, naming ClearScore, Modulr, Teya, Urban Jungle and Zilch, spanning payments, consumer finance, credit information and insurtech. Support on one hand, scrutiny on the other, and the same underlying message about growth outrunning its own controls.
Why governance lag lands on the marketing calendar#
Read the FCA's poor-practice list and it does not sound like a marketing document. Read it again with a campaign calendar open and it is nothing else. Every failing it names leaves the same scent, and the trail leads straight to a delayed approval.
The regulator found firms with incomplete, insufficiently detailed or missing meeting minutes. Minutes are where an approval decision is evidenced. No minute, no evidence, and a promotion that was in fact carefully considered becomes a promotion nobody can prove was considered at all.
It found firms that relied heavily on key individuals with limited contingency. In a scaling fintech that individual is usually the one person who can sign off a financial promotion, and their annual leave is therefore a company-wide publishing freeze that nobody has written down as a risk.
Sign-off is a person
One approver, no deputy, decisions recorded in a chat thread. The campaign ships on time until the week that person is away, and no minute exists to show why anything was approved.
Sign-off is a process
Named approver plus a named deputy, a standing agenda item, minuted decisions with the rationale attached. Slower on any single day, immune to any single absence, and evidenced when asked.
On the anti-money-laundering side the FCA is equally direct, saying We have seen firms rely too heavily on the financial crime controls of their parent company, and adding that firms cannot lean on off-the-shelf procedures designed for a different company. Borrowed controls are the governance equivalent of a borrowed den: warm enough until the weather turns.
The regime this all feeds into#
None of this is new law. The financial promotions regime has always required that a communication be fair, clear and not misleading, and the Handbook still puts it in one line: A firm must ensure that a communication or a financial promotion is fair, clear and not misleading. What has changed is how hard the regulator is now looking at whether a growing firm can show it meant it.
The channel makes no difference either. The FCA's finalised social media guidance says Financial promotions on all advertising channels should be fair, clear and not misleading, which closes the gap a growth team might hope existed between a prospectus and a fifteen-second vertical video.
The gateway that decides whether you can say anything at all#
Since February 2024 the ability to approve a financial promotion for an unauthorised person has been a permission rather than an assumption. The FCA states it plainly: A firm can only approve a financial promotion if the FCA has granted the firm permission.
The policy statement that created the gateway set the scope: all authorised persons that want to approve financial promotions for unauthorised persons will need permission from us. For a partnership-led fintech, that single sentence decides whether an affiliate, a comparison site or an introducer can legally carry your message.
The application page is where the marketing cost becomes visible, requiring that You must have appropriate policies to ensure the promotions you intend to approve are clear, fair and not misleading. Policies, in the plural, written down, before the first approval rather than after the first complaint.
The regulator has already reported what weak approval looks like in practice. Reviewing ten authorised approvers in May 2026 it found that some firms approved adverts with unsubstantiated claims or allowed retail investors to see promotions intended for professional clients. One firm had to run a remediation exercise. Both failures are marketing failures wearing compliance clothing.
The scale of that warning activity comes from the FCA's own account of its first year under the new strategy, which records that the FCA issued 2,329 warnings about unauthorised or potentially scam firms in 2025, alongside 650 social media takedown requests.
A financial promotions checklist for a firm that is growing fast#
This is the practical part, and it is deliberately unglamorous. Every item below is something the FCA has now said, in writing, that it looks for, which makes this financial promotions checklist an assembly of the regulator's own words rather than of agency instinct. No thicket of theory, just the five things a supervisor asks for.
Single-person dependency is the failing the FCA named first. A named deputy with the same permission turns one person's holiday from a publishing freeze into a normal week.
Record why a promotion was approved, what evidence substantiated each claim, and who challenged it. Missing and thin minutes are explicitly on the poor-practice list.
Off-the-shelf documents designed for another firm, or inherited from a parent, are called out by name. Procedures must describe how your firm actually operates.
Prove, at the targeting layer, that promotions intended for professional clients cannot reach retail investors. That failure has already been found in a published review.
The FCA found wind-down plans that were not current, practical or proportionate. If the plan predates your current spend and channel mix, it describes a company that no longer exists.
Do not skip the boring one#
The second step is the one that gets postponed, because minuting reasoning feels like bureaucracy rather than marketing. It is the only step that is evidence. When an information request arrives, the firm that can show its working is answering a question, and the firm that cannot is starting an investigation.
| What the FCA found | How it shows up in marketing | The fix |
|---|---|---|
| Governance not keeping pace with growth | Approval queue lengthens every quarter while headcount rises | Review the approval process on the same cadence as the budget |
| Incomplete or missing meeting minutes | No evidence a claim was ever substantiated | Minute the rationale and the challenge, not only the decision |
| Reliance on key individuals | One person's absence freezes all publishing | Name and train a deputy approver with the same permission |
| Off-the-shelf or parent-company procedures | Procedures describe a firm that is not yours | Rewrite against your actual channels and products |
| Wind-down plans not current or proportionate | Plan omits live commitments and media contracts | Refresh alongside the annual plan, not at renewal |
Growth-stage firms are not short of demand for this clarity. The FCA's own innovation report records that Applications to our Regulatory Sandbox and Innovation Pathways rose 49% in 2025. Firms are asking earlier, which is exactly the behaviour the Scale-up Unit exists to reward, and it will provide a dedicated point of contact for firms that qualify.
What to measure before the information request arrives#
Compliance reporting usually measures outcomes: approvals granted, promotions withdrawn, complaints upheld. Those are lagging indicators of a process that failed some weeks earlier. A fox does not track its quarry by the noise it made an hour ago, and the measures worth building are the ones that predict the failure instead.
Track three things about your financial promotions. Time from creative brief to approved promotion. The share of approvals resting on a single named individual. And the proportion of approved promotions with a complete minute attached. All three are cheap to count and all three answer a question the FCA has now demonstrated it will ask.
Annex 1 firms contacted
Approximate, per the FCA's 7 August 2026 statement, following 300 firms in late 2025.
Firms in the high-growth pilot
Asset management, wealth management and payments, July 2025 to March 2026.
Promotions amended or withdrawn
FCA interventions, 2024 Q4. The most recent quarterly figure published in the series.
Warnings issued in 2025
Warnings about unauthorised or potentially scam firms, from the FCA's first-year strategy release.
Context helps when this lands on a board agenda. Investment is not retreating from the sector: Innovate Finance reports that Global FinTech investment increased 21% in 2025 to $53bn, with the UK second. More capital chasing growth is precisely the condition in which governance falls behind, which is why the regulator moved now rather than in a downturn.
The cost side is worth stating carefully rather than dramatically. Research by Oxford Economics for LexisNexis Risk Solutions, which says We surveyed 254 senior compliance executives about their costs and compliance activities, put the UK annual compliance bill at £38.3bn. That survey reports 2023 costs, so treat it as a sense of scale rather than a current budget line.
A promotion you approved carefully and cannot evidence is, to a regulator, indistinguishable from one you never considered at all.
One number to take to the board: the share of live promotions with a complete, dated approval record attached. Not the number approved, the number evidenced. It is trivially countable, it moves within a quarter, and it converts a vague anxiety about the financial promotion rules into a line that goes up.
The fox does not test the ice by running across it. If you would rather have the sign-off layer built than described, that is what folkfox FinTech marketing does, alongside the brand strategy and content marketing work that keeps a claim substantiated before it reaches a channel. The same discipline governs how we run paid search and paid social for regulated firms, where the targeting layer is part of the compliance evidence rather than an afterthought.
Frequently asked questions#
What are financial promotions?
A financial promotion is an invitation or inducement to engage in investment activity, communicated in the course of business. In practice that covers almost all marketing of financial products and services, including social posts, paid ads, landing pages and affiliate content, whatever the channel.
Who can approve a financial promotion?
Only an authorised firm the FCA has specifically granted permission to approve promotions for unauthorised persons. The gateway commenced in February 2024, so a firm that could approve promotions before then cannot assume it still can without that permission.
What are the FCA rules for financial promotions?
The core rule is that a communication must be fair, clear and not misleading, set out in the Handbook at COBS 4.2. The FCA's finalised social media guidance confirms the same standard applies on every advertising channel, with no lighter treatment for short-form or influencer formats.
What should a financial promotions checklist cover for a scaling firm?
A named approver and a named deputy, written procedures specific to your firm rather than inherited, minuted reasoning for each approval, evidence that professional-only promotions cannot reach retail investors, and a wind-down plan refreshed against current spend and commitments.
Does the FCA financial promotions regime apply to social media and influencers?
Yes. The FCA's finalised guidance states that promotions on all advertising channels should be fair, clear and not misleading, and its enforcement record includes hundreds of social media takedown requests, so short-form and creator-led formats carry the same standard as any other.
Why are Annex 1 firms being contacted now?
The FCA is completing an anti-money-laundering review of the whole registered population, having engaged 300 firms in late 2025 and sent information requests to around 900 more in August 2026. It has said registration applications should be expected to take longer as a result.
Read more on this topic#
A marketing decision now carries a two year custodial maximum
The criminal end of the same regime, and why promotion sign-off stopped being a paperwork question.
Read the pieceThe rulebook just learned to speak machine
If the Handbook is machine-readable, your approval process can be checked against it continuously rather than annually.
Read the pieceThe fine fell 90%. The appointed representative ban did not
What happens when the firm carrying your promotion is not the firm that approved it.
Read the pieceThe regulator read the marketing plan and said no
A reminder that regulators now read growth plans as evidence, not as ambition.
Read the piece
Scaling faster than your sign-off queue?
folkfox builds financial promotions processes that survive an information request: substantiated claims, evidenced approvals, and targeting that proves who a promotion could and could not reach.