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Do not rely on an advert’s FCA logo, a firm’s trading name or a statement that it is “FCA approved”. Identify the exact promoter and offer, check the firm in the FCA Firm Checker, then inspect the matching entry in the Financial Services Register. Confirm that the firm has permission for the product being promoted and, where an unauthorised business is involved, that the named approver has specific permission to approve that type of financial promotion. Finally, test whether a stated exemption genuinely applies and assess whether the claims are fair, clear and not misleading.
Approval is not the same as an FCA endorsement of an investment or a guarantee that you will be paid. The business that prepared the promotion may remain responsible for its substantive content, while the authorised approver has duties to comply with FCA financial-promotion rules. Responsibility is fact-specific, so record both parties and the exact version of the communication.
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What counts as a financial promotion?
For UK regulatory purposes, a financial promotion is generally an invitation or inducement, communicated in the course of business, to engage in investment activity or claims-management activity. The format does not decide the issue. A promotion can be an advert, brochure, email, website page, telephone script, app screen or social-media post. A short-lived story or a message sent privately can still require analysis if it is a business communication.
The first practical question is therefore not “Does this look like an advert?” but “What action is this communication encouraging, who sent it, and what regulated activity or product is involved?” A post that encourages people to buy an investment, transfer money to a trading service or use a claims-management service may fall within the financial-promotion regime even if it uses educational language.
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The legal perimeter has exceptions and detailed definitions. The FCA’s guidance on approving promotions and its perimeter guidance explain the circumstances in which the restriction in section 21 of the Financial Services and Markets Act 2000 applies. Read the FCA guidance on approving financial promotions and, for technical questions, PERG 8.
What “approved” means—and what it does not mean
An unauthorised business generally cannot communicate a financial promotion unless an authorised person communicates it or approves it, or a statutory exemption applies. An authorised firm that approves the communication must be permitted to do so and must ensure that the promotion complies with the FCA’s rules, including the requirement to be fair, clear and not misleading.
That is a compliance sign-off, not an investment-quality assessment. The FCA says, “We don’t endorse products, we only authorise the business that provides them.” An FCA authorisation or a firm’s approval permission does not mean the regulator has checked the investment’s prospects, guaranteed a return or accepted the commercial claims. Treat statements such as “FCA-backed”, “FCA-certified” or “the FCA approves this investment” as warning signs unless they are being used in a narrow, factual way.
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Step-by-step: check a promotion before you rely on it
1. Preserve the exact offer and identify the parties
Save a PDF, screenshot or printout of the complete promotion, including footnotes, risk warnings, hyperlinks and the date you saw it. Record:
- the legal name and trading name of the promoter;
- the website domain, email address, telephone number and physical address shown;
- the product or service, including the proposed investment or claims-management activity;
- the platform, social-media account or publication where it appeared;
- any statement naming an authorised firm or an approver; and
- the URL, date and time, if the communication was online.
Compare all of those details with the regulator’s records. Fraudsters often copy the name, logo, address or registration number of a genuine authorised firm. The FCA Register includes unauthorised firms and known clone details, so a familiar name by itself is not proof that you are dealing with the genuine business.
2. Use the FCA Firm Checker to establish basic status
Start with the FCA’s consumer guidance, How to check a firm or individual is authorised, and use the linked Firm Checker. Search the exact legal entity, not just a brand name. Confirm that the firm is authorised and that its listed permissions cover the product or service being offered.
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Do not confuse registration with authorisation. A firm can be registered for a limited purpose yet lack permission to provide a regulated service that requires authorisation. A result that merely says “registered” does not answer whether the business can lawfully offer the product in the promotion.
3. Open the matching Financial Services Register entry
The Financial Services Register is the official public record. Use the exact legal entity, reference number, address and trading names to make sure you have the right record. Review:
- the firm’s status and regulatory reference number;
- the permissions and regulated activities listed;
- any restrictions, requirements or warnings;
- appointed-representative relationships, where relevant;
- the firm’s ability to approve financial promotions for unauthorised persons; and
- historical information that may show what the firm could do when the promotion was issued.
A current entry cannot automatically validate an old advert. If the communication is from an earlier period, compare its date with the Register’s historical information and with the dates on the firm’s permissions.
4. Match the permission to the product or service
Authorisation is not a blanket licence for every financial activity. Read the permission description and compare it with what the promotion actually offers. For example, a firm authorised for one class of investment business may not have permission for a different product, client type or activity. If the wording is unclear, ask the firm to identify the precise permission on its Register entry; do not accept a generic statement that it is “FCA regulated”.
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If the promoter is unauthorised, find the authorised firm that supposedly approved the communication. Then check that firm’s Register entry for the ability to approve financial promotions for unauthorised persons and for any limits on that permission.
Since 7 February 2024, an authorised firm generally needs FCA permission to approve financial promotions for unauthorised persons. The main rule has exemptions and transitional arrangements, but ordinary authorisation alone does not establish that a firm may approve every third party’s promotion. The FCA explains the application and permission regime in Applying to approve financial promotions for unauthorised persons and in SUP 6A.
Look for the exact authorised entity named in the advert or approval statement. A group company, appointed representative or similarly branded business may be a different legal person. If the advert names no approver, or the named firm’s record does not show the relevant ability, treat that gap as unresolved rather than assuming approval.
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6. Test any claimed exemption
Some promotions can fall outside the approval requirement in limited circumstances. FCA guidance describes exemptions for certain promotions prepared by the approving firm itself, by an unauthorised member of its corporate group, or by its appointed representative for activities for which the authorised firm accepts responsibility. The scope depends on the precise facts and legal conditions.
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7. Read the promotion for balance and clarity
A valid approval status does not cure misleading content. Check whether the communication:
- explains material risks near the associated benefit or return claim;
- states fees, commissions, lock-ins, eligibility conditions and withdrawal limits clearly;
- uses realistic, supportable performance language rather than certainty or urgency;
- avoids presenting a professional-client opportunity as suitable for everyone;
- makes clear who is providing the product and who approved the communication; and
- keeps important information out of tiny print, hidden tabs or a separate page that the main claim does not mention.
These checks matter even where the firm appears on the Register. The FCA’s consumer guidance on misleading financial promotions explains how to recognise and report promotions that create an unbalanced or unrealistic impression.
8. Stop and report when records and claims do not match
Do not click through, transfer funds or provide identity documents while a material mismatch remains. Capture the evidence before the page disappears. Check the Register first, then use the FCA’s reporting routes for an authorised firm’s suspected misconduct or for a suspected scam or unauthorised firm. Include the exact promotion, the account or domain used, payment instructions, dates and the Register results you found.
Which FCA tool answers which question?
| Check | Best source | What it can establish | What it cannot establish by itself |
|---|---|---|---|
| Basic firm status | FCA Firm Checker, through the consumer authorisation guidance | Whether the searched entity appears authorised or has another recorded status. | That the entity has permission for the particular product, or that a specific advert is compliant. |
| Detailed permissions and identity | Financial Services Register | The official entity, reference number, permissions, restrictions, historical information and recorded ability to approve promotions. | That a website visitor is actually dealing with that entity rather than a clone. |
| Third-party promotion approval | Approver’s Register entry and the approval statement | Whether the named authorised firm has the relevant ability to approve promotions for unauthorised persons. | That the approver actually reviewed this version or that every claim is true. |
| Section 21 exceptions | FCA Handbook PERG 8.9 | The legal categories in which the restriction may not apply. | That a promoter’s unsupported assertion satisfies the conditions. |
| Misleading content and reporting | FCA consumer guidance | Examples of imbalance, hidden information and reporting options. | A compensation decision or a guarantee that losses will be recovered. |
Who is responsible for the promotion?
There may be more than one responsible party. The firm that approves a promotion must take reasonable compliance responsibility for the communication and ensure it meets FCA financial-promotion rules, including being fair, clear and not misleading. The person or business that prepared the content may be principally responsible for the substantive claims. The FCA Handbook says the allocation depends on the facts.
| Party | Typical responsibility | Questions to ask |
|---|---|---|
| Promoter or product provider | Creates or distributes the invitation or inducement and supplies the underlying facts, terms and performance claims. | Who wrote the copy, supplied the data and receives the customer’s money? |
| Content preparer | May bear primary responsibility for the accuracy and substance of statements, depending on its role and the evidence supplied. | Who prepared the claims, risk disclosures and illustrations? |
| Authorised approver | Must have the required permission (unless an exemption applies) and ensure the promotion complies with applicable FCA rules before approving it. | Which legal entity approved this exact version, on what date and under what permission? |
| Appointed representative or group entity | May prepare or distribute a promotion within a specific relationship or exemption, where the authorised firm accepts responsibility for the relevant activity. | Is the relationship current, and does the authorised firm accept responsibility for this activity? |
The approver is not automatically the only responsible party. Conversely, a promoter’s logo or a reference to an authorised group does not prove that the group approved the communication. Preserve the names, dates and version of the promotion so that responsibility can be assessed against the actual facts.
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What changed on 7 February 2024?
From 7 February 2024, authorised firms generally need FCA approver permission before approving financial promotions for unauthorised persons. The change is aimed at firms that sign off promotions produced by businesses outside the FCA’s direct authorisation perimeter. It does not mean every approval made before that date was invalid, nor does it remove the legal exemptions.
Firms that applied before 7 February 2024 may be covered by transitional arrangements. Check the firm’s Register record and the FCA’s current explanation rather than assuming that a historical approval or an application automatically confers continuing permission. The FCA updated the Register to show firms’ ability to approve financial promotions, making the entry a central part of the check.
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How to spot clones and misleading authority claims
Clone fraud usually combines a real firm’s identity with different contact details. Compare the domain, telephone number, email address and bank-account information in the promotion with the genuine details on the Register. A close spelling, a different country code or a free email address can be decisive. Contact the genuine firm using the details on its Register record, not the number in the advert, if you need confirmation.
Be cautious when a promotion:
- uses “FCA approved” without naming the legal entity that approved it;
- shows an FCA logo or reference number but omits the firm’s actual permissions;
- promises guaranteed, unusually high or time-limited returns;
- pressures you to move the conversation to an encrypted messenger;
- asks for payment to an account in a different person’s or country’s name; or
- claims that regulation eliminates investment risk.
None of these signs alone proves fraud, but each warrants an independent check. An authentic Register entry does not authenticate the person who contacted you.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.A record-keeping checklist you can reuse
For a significant investment or claims-management decision, keep a short audit file. It should contain:
- A dated copy or screenshot of every page, email, post and risk warning.
- The promoter’s legal and trading names, company details, domains and contact information.
- The Firm Checker result and the exact Register record and reference number.
- The permissions relevant to the product or service, including any restrictions.
- The named approver’s Register entry and evidence of its ability to approve promotions for unauthorised persons, if applicable.
- The stated exemption and the facts said to support it, if the promoter relies on one.
- Your notes on fees, risks, liquidity, eligibility and performance claims.
- Copies of questions sent to the firm and answers received through independently verified contact details.
- The date and method of any report to the FCA or another authority.
This record helps distinguish a genuine change in a firm’s permissions from a later alteration to an online advert. It also gives the FCA useful evidence if the promotion disappears.
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Worked examples
An unauthorised business names an approver
An investment website says it is not authorised but displays the name of an authorised firm as its “FCA promotion approver”. Search the investment website’s legal entity in the Firm Checker and Register first. Then open the approver’s record and verify the specific ability to approve promotions for unauthorised persons. Match the product permission to the investment being offered, preserve the exact advert and look for any restriction or historical mismatch. If the approver has only ordinary authorisation, or the product is outside its permissions, the statement does not establish lawful approval.
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A genuine firm’s identity appears on a different domain
You find an advert using the name and reference number of a real firm, but its telephone number and bank details differ from the Register. Treat the communication as potentially cloned. Do not use the advert’s contact details to verify it. Call or email the genuine firm using independently sourced Register details and report the suspected clone if the firm confirms it is not theirs.
A promotion claims an exemption
A group company says no separate approval is needed because it is connected to an authorised firm. Check whether the promotion was prepared by the authorised firm, by an unauthorised group member within the relevant exemption, or by an appointed representative for an activity the authorised firm accepts responsibility for. If the facts are not stated or do not fit the narrow legal conditions, the exemption claim remains unproven.
What the FCA’s 2026 approver review means for consumers
On 27 May 2026, the FCA reported a review of 10 authorised firms that approve financial promotions. It gave examples of firms approving unsubstantiated claims and allowing retail investors to see promotions intended for professional clients. The sample shows that approval controls can fail; it is not a market-wide failure rate and should not be read as evidence that every approver is deficient.
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What to do when the answer is still unclear
If you cannot match the promoter, product permission, approver or exemption to the FCA records, do not proceed on the strength of a marketing claim. Ask for the legal entity, the approver’s name, the approval date and the permission relied on. Verify the answer through the Register rather than through links supplied in the promotion.
For suspected unauthorised activity, a clone or misleading content, use the FCA’s reporting channels after checking the Register. If you have already sent money, contact your bank immediately and preserve every communication. FCA reporting does not guarantee recovery, but prompt, complete evidence can help the regulator and your payment provider assess what happened.
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