FCA Social Media Compliance for Banking & Financial Promotions

On March 26, 2024, the Financial Conduct Authority (FCA) published its finalised guidance (FG24/1) on financial promotions via social media. This guidance highlights compliance risks and the growing influence of social media marketing in financial services.

With FCA compliance for banking promotions becoming stricter, firms must ensure their marketing strategies align with regulatory requirements while maintaining a strong online presence.

Who Needs to Follow FCA Social Media Compliance?

This guidance applies to:

• Financial institutions and banks conducting marketing activities online.
• Influencers & affiliate marketers promoting financial services on social media platforms.
• Trade associations representing financial institutions and digital marketing agencies in banking.

Key Takeaways from FCA’s Social Media Compliance Guidelines

1. Social Media Financial Promotions Are Platform-Agnostic

• Any social media post that promotes financial services falls under FCA’s scrutiny.
• Private channels like Discord, Telegram, and Reddit are also covered under UK banking compliance.
• Crypto influencers (“finfluencers”) using memes or viral content must ensure full compliance with FCA regulations.

2. Every Promotion Must Stand Alone in Compliance

• Each social media advertisement must be individually compliant, whether it’s a tweet, story, or LinkedIn post.
• The FCA provides clear social media advertising rules for platforms like Instagram, Facebook, LinkedIn, and TikTok.

3. Financial Advertising Must Be Clear & Balanced

• All financial marketing content must:
  • Be transparent, accurate, and not misleading.
  • Provide a balanced overview of risks and benefits.
  • Include FCA-mandated risk warnings for high-risk investments (HRIs).

4. Banks & Firms Are Responsible for Influencer Marketing Compliance

• Financial institutions must actively monitor and audit influencer promotions.
• Affiliate marketers using referral links for financial services must follow FCA advertising standards.
• Influencers promoting unauthorised financial services without FCA approval risk legal penalties, including imprisonment and fines.

5. Affiliate Marketing & Third-Party Content Risk Management

• Financial services firms remain responsible for third-party promotions, even if they didn’t create the original content.
• FCA-compliant affiliate marketing strategies require strict oversight and transparent ad disclosures.

Key Compliance Questions for Banks & Financial Marketers

1. Is Your Social Media Content Balanced?

• Does your financial promotion fairly present risks and rewards?
• Are your advertisements appropriate for your target audience?

2. Is Social Media the Right Channel for Your Financial Product?

• Complex financial instruments (e.g., cryptoassets, high-risk loans) may not be suitable for quick engagement marketing.
• FCA highlights BNPL promotions as high-risk, requiring clear disclosures.

3. Are Risk Warnings Prominent?

• Does your social media ad feature full and visible risk warnings?
• Ensure compliance with FCA’s risk disclosure framework listed in FG24/1 Table 1.

4. Are You Applying Marketing Restrictions Correctly?

• High-risk financial promotions must comply with COBS 4.12A, 4.12B, and COBS 22.
• Consumer marketing strategies should be tested and optimised for regulatory adherence.

5. How Are You Preventing Non-Compliant Content Sharing?

• Financial promotions may be reshared, leading to compliance breaches.
• FCA compliance guidelines require monitoring of forwarded, embedded, or quoted content.

6. Are Your Affiliate Marketers Following the Rules?

• Banks and fintech firms must track all financial promotions made by affiliates.
• If an affiliate post includes referral links, the financial firm is liable.
• Ensure compliance with ASA online affiliate marketing rules.

FCA Compliance Checklist for Banking & Social Media Promotions

✅ Ensure all financial promotions are fair, clear, and not misleading.

✅ Include FCA-mandated risk warnings where required.

✅ Monitor and audit influencer and affiliate promotions.

✅ Check whether social media is the right platform for your financial service.

✅ Follow COBS 4.12A, 4.12B, and COBS 22 regulations.

✅ Avoid non-compliant resharing of promotional content.

Tools to Ensure FCA-Compliant Social Media Marketing

Managing FCA compliance for social media promotions can be challenging. However, several regulatory technology (RegTech) solutions help financial firms ensure their social media marketing aligns with compliance rules:

1. MarketBeam

✅ ASA &FCA-compliant social media publishing with pre-approval workflows for financial content.
✅ AI-driven content monitoring ensures promotions meet financial advertising guidelines.
✅ Automated risk warnings & disclosure management for regulated industries like banking and fintech.

✅ Social media compliance tool for banks & wealth management firms.

✅ Real-time content approval & monitoring to prevent non-compliant posts.

2. Hearsay Systems

✅ Social media compliance tool for banks & wealth management firms.
✅ Real-time content approval & monitoring to prevent non-compliant posts.
✅ Helps financial brands follow ASA & FCA disclosure guidelines.

3. Proofpoint

✅ Monitors influencer & affiliate marketing for non-compliant financial promotions.
✅ Identifies and flags high-risk content before publication.
✅ Ideal for finfluencer marketing compliance.

4. Shield (for LinkedIn)

✅ Tracks employee advocacy posts in the financial sector.
✅ Helps banks manage social media risk exposure.
✅ Ensures marketing teams comply with FCA’s financial promotions policy.

5. Sprinklr

✅ AI-powered compliance monitoring for banks & fintech companies.
✅ Flags non-compliant content across multiple platforms, including Instagram, Facebook, and Twitter.
✅ Automates compliance reports & risk analysis for FCA regulatory audits.

By using these tools, financial firms, banks, and fintech marketers can efficiently manage social media compliance, prevent FCA violations, and protect brand reputation.

Next Steps for Social Media Compliance in UK & US Banking

The FCA’s FG24/1 guidance replaces its 2015 social media guidelines, reflecting significant digital marketing changes in the financial sector. While no new legal obligations have been introduced, the guidance clarifies how existing UK banking compliance laws apply to modern financial promotions.

Consult a Financial Compliance Expert

For expert advice on financial social media compliance, contact our FCA banking regulatory specialists.

Final Thoughts on FCA’s Financial Promotions Guidance

The FCA’s revised guidelines mark a crucial shift in how banks, fintech firms, and financial marketers must handle social media advertising. To ensure compliance, firms must:

• Monitor influencer & affiliate marketing strategies.
• Improve consumer transparency through fair and balanced messaging.
• Mitigate risk warnings & non-compliant sharing.

By implementing FCA-compliant financial marketing strategies, banking institutions can enhance consumer trust, legal security, and brand credibility in the evolving digital finance landscape.