This page gives an analysis and insights on the data collected from 1 January 2024 to 31 December 2024. It covers action taken against authorised firms breaching financial promotion rules and referrals and investigations into unregulated activity.
Financial services are essential for everyone in the UK. Good quality marketing information helps ensure consumers get good outcomes. Unclear and misleading marketing is a big concern because financial products are complex and often long-term. Our data shows we are increasing our interventions and we continue to focus on identifying authorised and unauthorised firms and/or individuals causing consumer harm.
This data gives an overview of our work to improve and raise standards across the financial services markets. Our aim is to ensure that consumers receive information about financial promotions which is clear, fair and not misleading, helping them to make informed decisions before spending their money. It compiles the data and themes reported in our quarterly financial promotions’ publications[1] during 2024.
In 2024 we continued our work with registered cryptoasset firms to comply with the Cryptoasset financial promotions regime[2] and took strong action against firms that were illegally promoting cryptoassets to UK consumers. We also introduced the financial promotions approval gateway[3], requiring firms that want to approve financial promotions on behalf of unauthorised firms outside of their group to apply to us for approver permission. We continued to build on our work with finfluencers and took targeted action against 20 individuals who were interviewed under caution during the latter part of last year. We continue to work with social media platforms to disrupt this activity, but significant work is still needed from all social media platformsto stop illegal financial promotions.
We expect firms to pay attention to the needs of customers with characteristics of vulnerability to make sure they are treated fairly. We continue to assess firms against the Consumer Duty and have seen examples where standards are not being met across several sectors. We have seen firms communicate information to retail customers in unclear, unfair and potentially misleading ways, with some promoting products or services in a way that misleads customers about the risks involved. The Consumer Duty requires firms to put consumers at the heart of their business, produce products and services that are designed to meet customers’ needs and to provide fair value.
We expect firms to read this and take necessary steps to ensure they deliver good consumer outcomes. We will continue to intervene where we identify authorised and unauthorised firms and/or individuals causing consumer harm.
What’s included in the data
- key messages
- examples of our work on financial promotions during 2024:
- reducing and preventing serious harm
- setting and testing higher standards
- promoting competition and positive change
- information on how to report a misleading financial advert or potential scam
1. Key messages
- In 2024 we increased our interventions in response to failures in financial promotions in both authorised firms and unauthorised firms and individuals. We are still concerned about the levels of compliance with the financial promotions’ rules and will keep focusing on this area to reduce consumer harm.
- Following our interventions, for authorised firms we had 19,766 promotions amended/withdrawn. This is an increase of 97.5%, compared to 10,008 in 2023.
- We have accepted voluntary requirement requests from 18 firms and used our own initiative powers on 2 firms to restrict their ability to communicate or approve financial promotions.
- For unauthorised firms and individuals, we issued 2,240 alerts in 2024. While this is a decrease of 2% from 2,286 in 2023, the alerts remain high compared to historical levels. Our alerts continue to warn the public when they may be dealing with an unauthorised, scam or clone firm.
- We have continued our work to implement the cryptoasset financial promotions regime. We have published our findings of good and poor practice[4] following our review of firms’ compliance. This has helped raise awareness of the rules and highlighted our work to protect people and promote a competitive, sustainable crypto sector.
- We used data and technology to increase our capacity to identify and assess around 480,000 new websites that could be providing or promoting financial services or products without our permission. This resulted in reviews of just over 3,700 websites and social media platforms and led to over 1,600 alerts to warn UK consumers about these unauthorised firms.
- We took targeted action against finfluencers who may be touting financial services products illegally. As a result, 20 finfluencers were interviewed under caution using our criminal powers and we issued 38 alerts against finfluencer social media accounts that may contain unlawful promotions. There is still a lot of work to be done by all social media platforms. We want to see platforms take stronger action to proactively identify and stop illegal promotions being pushed on consumers.
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2. Our work
Trends and themes identified and action taken
Our work with Claims Management Companies (CMCs)
As highlighted throughout our 2024 quarterly publications, we have seen an increase in activity with CMC firms – this is widespread across both authorised and unauthorised firms.
In 2024, our engagement with 46 authorised CMCs resulted in 9,197 financial promotions being amended/withdrawn (46% of the 19,766 total). Some of the most common breaches involved CMCs who offered their services for housing disrepair or motor finance claims. The consumers being targeted by housing disrepair claim promotions may display characteristics of vulnerability. The Consumer Duty requires firms to pay attention to the needs of customers with these characteristics to make sure they treat them fairly. With the motor finance claims, it is important that firms are ensuring consumers are made aware of the current situation on motor finance complaints[5].
We have also seen unauthorised firms use social media to promote housing disrepair claims. Consumers are then referred to other fee-charging firms without setting out the free options available to them. Seeking out consumers in this way is a regulated activity. We are concerned that some of these firms also promote debt management services, looking to capitalise on the cost of living crisis. We continue to focus our work to disrupt these activities, including seeking to remove unlawful financial promotions.
In 2025 we will continue to monitor this sector closely and take action where appropriate.
Our work with firms offering debt advice and debt solutions
We are still working actively with firms promoting and advertising debt advice and solutions to consumers. We continue to take action against unauthorised firms placing promotions in this area, especially on social media platforms like TikTok. Vulnerable consumers are pushed towards fee-based services that may not be appropriate for them, when they could have benefited from free sources of debt advice and potentially more suitable solutions.
We continue to use our tools and powers to take appropriate action against firms to prevent serious harm to consumers in this area.
Examples of our interventions
2.1. Reducing and preventing serious harm
Proactive action, monitoring new websites
We use various tools and sources to proactively identify websites and social media that promote financial services without appropriate authorisation. With thousands of websites created every day, we have used data and technology to increase our capacity to identify and assess around 480,000 new websites that could be providing or promoting financial services or products without our permission. This resulted in reviews of just over 3,700 websites and social media platforms. This work led to over 1,600 alerts to warn UK consumers about these unauthorised firms.
Finfluencers
In March 2024, we finalised guidance on financial promotions on social media. Social media is an increasingly important part of firms’ marketing strategies, enabling firms to reach large audiences. Firms working with affiliate marketers, like finfluencers, should take proactive responsibility for how their affiliates communicate financial promotions.
We have seen more young people falling victim to scams and finfluencers can often play a part. Nearly two-thirds (62%) of 18 to 29-year-olds follow social media influencers, with 74% of them saying they trusted their advice. Additionally, 9 in 10 young followers said they have been encouraged to change their financial behaviour.
Unauthorised persons who promote financial products or services that are subject to regulation without the approval of a FCA authorised person may be committing a criminal offence. In October 2024, we took targeted action against finfluencers who may be touting financial services products illegally. As a result of this work, 20 finfluencers were interviewed under caution using our criminal powers and we issued 38 alerts against finfluencer social media accounts that may contain unlawful promotions.
We continue to work with social media platforms to disrupt this activity. While there has been some progress, there is still a lot of work to be done by all social media platforms. The responsiveness to our requests for removing unlawful content varies and some platforms, like X and Discord, have refused to remove unlawful content except in exceptional circumstances. We want to see platforms take stronger action to proactively identify and stop illegal promotions being pushed on consumers.
2.2. Setting and testing higher standards
To protect consumers from misleading, unclear or unfair financial promotions, we have made several recent changes to strengthen the financial promotions regime. More changes are scheduled.
Cryptoasset financial promotions regime
The cryptoasset financial promotions regime came into force on 8 October 2023 and has been live for over a year. We know this has been the first conduct regime for cryptoasset firms and that adjusting to new regulation can be challenging.
Throughout 2024, we conducted reviews to test compliance with these rules. Based on these, we gave feedback to firms and took action where we identified breaches. Firms have also asked for more guidance, and we have published extensive material setting out our expectations including:
- Guidance on cryptoasset financial promotions in FG23/3[6].
- Guidance on financial promotions on social media in FG24/1[7].
- Good and Poor practice[8] on firms’ preparations for this regime.
- Good and Poor practice[7] on firms’ implementation on the Direct Offer financial promotion rules.
We expect firms to consider these publications and continue to drive up standards in the sector. We have seen firms relying on industry comparisons to benchmark what is acceptable. Given the levels of poor practice in the market, firms should not be doing this. Instead, we expect firms to engage with us directly to raise standards across the sector.
We will also review firms’ compliance with regulatory requirements, including the financial promotions regime, as part of any application to be authorised under the future financial services' regulatory regime for cryptoassets. We published a road map[9] outlining our planned policy publications for cryptoassets where we are seeking feedback.
We have continued to take strong action against firms illegally promoting cryptoassets to UK consumers. One aspect of our supervisory approach has been examining the role of regulated/registered firms providing fiat-to-crypto on/off ramp services to unregistered cryptoasset firms. We expect regulated firms to play their part in ensuring the protections offered by the financial promotions regime are effective, and that they are not supporting firms who are illegally promoting cryptoassets. We have recently published additional information for firms on our website[10] to help them understand our expectations here. All firms intending to engage or partner with unregistered cryptoasset firms should carefully consider this content.
Section 21 Gateway
From 7 February 2024, authorised firms have needed our permission to approve promotions for unregulated persons. Firms that approve financial promotions must have the required competence and expertise as well as adequate systems, controls and processes to ensure that any promotions they approve comply with our rules. The approval process being conducted under the section 21 gateway is not just a formality.
Firms must now notify us when approving a new promotion, where an amendment is made or withdrawal, when it relates to high-risk products subject to a retail mass-marketing ban or qualifying cryptoassets. We have been monitoring section 21 approvals and taking action where we see promotions being inappropriately approved.
We are assessing the applications of firms who have applied for permissions to be section 21 approvers. We can and will refuse firms where we consider doing so is necessary to protect consumers.
Feedback to approvers on REP024 reporting
Firms that have applied for section 21 approver permissions must submit regulatory returns every 6 months. Following our monitoring of the initial sets of returns after the regime went live in February 2024, we have contacted several approvers to reiterate our expectations, including that approvers:
- Should get information from their clients about complaints about approved financial promotions so approvers can include this in their ongoing monitoring and reporting.
- Who do not charge separately for section 21 approvals, because these are included within a wider service, should attribute a proportion of their revenue to section 21 approvals for reporting purposes
Section 21 approvers taking on new clients
We expect firms providing Section 21 approval services to have contracts which encompass the full range of financial promotions which their clients use to communicate.
We have engaged with a Section 21 approver firm about a client we believed to be communicating financial promotions in breach of Section 21 of the Financial Services and Markets Act 2000 (FSMA), which is a criminal offence. Following our engagement with the firm, it amended its processes to require prospective clients to geoblock their websites, social media pages and mobile applications before allowing them to proceed with the onboarding journey.
This action ensured that clients are not communicating financial promotions in breach of the rules and UK consumers are not harmed by engaging in investing via illegal financial promotions.
Proactive monitoring of website changes
Section 21 approver firms must take reasonable steps to monitor the continuing compliance of financial promotions they have approved.
We have seen a good practice example where a Section 21 approver had introduced software to monitor approved financial promotions on their clients’ websites. The software detects changes to the website the approver can proactively investigate. This helps the approver ensure that the promotions consumers receive are, and continue to be, the same as the version that was approved.
Raising market standards
During the year, we proactively reviewed financial promotions of firms who offer:
- claims management activity for motor finance claims
- later life lending
We also reviewed firms who repeatedly failed to comply with the financial promotions’ rules. In March, following our publication of the Finalised guidance on financial promotions on social media (FG 24/1)[10], we also reviewed 411 social media promotions across 21 firms.
This work resulted in 1,633 (8% of the 19,766) promotions being amended or withdrawn during 2024.
We take non-compliance with our rules seriously and will consider taking further action, including using our intervention powers, where necessary.
2.3. Promoting competition and positive change
Buy now pay later consultation
In October 2024, we welcomed[11] the government’s consultation on the regulation of the currently exempt buy now pay later (BNPL) products.
BNPL can benefit consumers by giving them more payment options and support merchants in selling their goods and services. But, as with other credit products, there are also risks and the potential for harm. We want to ensure those who find BNPL helpful can still benefit from it, firms can innovate and grow and consumers are appropriately protected.
Our regulation of BNPL aims to ensure good outcomes for borrowers and alignment with rules already in place for other credit providers. Firms will also be subject to the Consumer Duty. We will consult on financial promotions requirements for BNPL.
We will continue to review and assess firms against the previously published Dear CEO Letter[12] and applicable CONC rules and guidance. We took forward cases with 4 firms who offered BNPL. Our intervention resulted in 856 promotions being amended or withdrawn.
3. How to report a misleading financial advert or potential scam
Report a financial advert or promotion[13] that you think is misleading, unfair or unclear.
Report a scam[14], authorised firm or individual to us.
Our casework will usually involve confidential information, which means we are usually limited in being able to provide further information about particular cases. Find out more about the information we can share[15].
Disclaimer
- The figures reported within this data are accurate at the time of publication. However, they can be subject to change depending on any ongoing work with a firm.
- The amend and/or withdraw outcome figure is based on cases closed during this period and will be determined by the number of promotions across various platforms.
Copyright
The data on this page is available under the terms of the Open Government Licence[16].