Financial promotions quarterly data 2023 Q4

This page gives a summary of data generated between 1 October 2023 and 31 December 2023 from our actions against firms breaching financial promotion rules, and referrals and investigations into unregulated activity.

This data provides an overview of how we are working to improve standards across the market so that consumers are provided with clear and fair financial promotions which are not misleading.

What’s included in the data

  • Key messages
  • Authorised firms
    • number of financial promotions reviewed during this period
    • number of closed cases where promotions have been amended and withdrawn, including split across sectors, excluding cases which are still ongoing
  • Unauthorised firms
    • number of unauthorised reports received, and alerts issued
  • Examples of our work on financial promotions during 2023 Q4:
    • 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

Key messages

  • Our interventions in 2023 Q4 resulted in 1,004 promotions being amended or withdrawn by authorised firms.
  • We issued 793 alerts on unauthorised firms and individuals, 6% of these were clone scams.
  • On 8 October 2023, our financial promotion rules for cryptoassets went live. These rules require financial promotions to be clear, fair, and not misleading, firms to display clear risk warnings, to disclose the firm’s regulated status and cease promoting any form of incentive to invest. Below, we have set out some of our findings since these rules went live.
  • For crypto firms who successfully applied for a modification by consent, the customer journey financial promotion rules came into force on 8 January 2024. We are now conducting reviews to test the level of compliance with these rules.   We will take action where we see breaches, using our supervisory tools and potentially using enforcement action, where necessary.

Authorised firms

Number of promotions reviewed

In 2023 Q4 we reviewed 407 financial promotions from multiple sources:

31% from our proactive monitoring

31% from consumers

12% from UK Regulators

17% from different areas of the FCA

9% from firms


Following our intervention, in Q4 we had 1,004 promotions amended/withdrawn.

Table 1: Number of cases with interventions and amend/withdraw outcomes

2023 Q4

0 s137S (the Banning Power) directing a firm to withdraw financial promotions

1 Own Initiative Action for Imposition of Requirements (OIREQ) was approved, restricting the firm’s ability to communicate or approve financial promotions

1 Voluntary Application for Imposition of Requirements (VREQ) was accepted, restricting the firm’s ability to communicate or approve financial promotions

0 Undertaking and Attestation

1,004 promotions were amended or withdrawn following our intervention with 72 authorised firms

Chart tips: hover over data series to view the data values and filter the data categories by clicking on the legend.


Figure 1 shows the split across sectors.


Data table


Figures rounded to the nearest percentage.

The retail investments and retail lending sectors had the highest amend/withdraw outcomes, totalling 95% of our interventions with authorised firms. 

Some of the most common breaches involved debt advice firms, credit broker firms, cryptoasset firms and Enterprise Investment Scheme (EIS) providers.

Unauthorised firms

Number of reports received

In 2023 Q4, we received 6,143 reports about potential unauthorised business.  

We issued 793 alerts about unauthorised firms and individuals. 6% of these related to clone scams, which is where fraudsters use details such as the name and address of authorised firms and individuals, and a 'firm registration number' (FRN) to suggest they are genuine. Many of these involved breaches of the financial promotion restriction online. In almost all cases we asked for the websites to be taken down.

Examples of our interventions - authorised and unauthorised firms 

Reducing and preventing serious harm   

Taking assertive action against an s21 approver


A firm advised us that it proposed to start approving financial promotions (s21 approvals) for cryptoassets. But on the same day as notifying us we became aware that the firm had already approved several financial promotions for an unregistered crypto asset entity.

Action taken

We reviewed the firm's systems and controls and the competency and experience of staff and found they were not adequate. In addition, we identified several breaches with the approvals they had already undertaken. We invited the firm to apply for a VREQ which prevents them from providing s21 approval for cryptoassets and requires them to withdraw any approvals already given. The firm agreed to this course of action.

Preventing consumer harm by imposing requirements where multiple rule breaches were identified


We intervened where a regulated firm was also acting as an ISA Manager. We were concerned that consumers were being presented materials about investment opportunities where there was significant risk that those materials were inaccurate and / or were potentially misleading. The firm was providing services to companies issuing investment products but did not conduct any due diligence regarding these investments. The firm was also unable to demonstrate it fully understood the products it was distributing and had not considered how they were suitable for its target market.  The firm had inadequate systems and controls and resources to ensure these investments were distributed appropriately and in the best interest of its clients.


Due to multiple rule breaches and the potential risk to consumers, we used our Own Initiative powers to stop the firm undertaking regulated activities for any new investments or new funds into existing investments.

Contract For Differences (CFD) firm with shared social media profiles


The firm was operating shared social media profiles across its group companies and potentially a global website, so it was not clear which entity consumers were engaging with. In addition, there was a misleading comparison of average leverage with the firm’s competitors and the prominence of the warning explaining the percentage of consumers that lose money with this provider was not sufficient.


The firm have confirmed that the previously identified website was not intended for UK consumers. They implemented an auto redirect based on geo-location and IP address, which means UK consumers are automatically directed to the UK version of the website. In addition, they have created specific UK social media accounts, so that they can now be easily distinguished from the other global entities. The comparison of average leverage with competitors was removed and the prominence of its loss percentage warning was improved.

Consumer credit firm with unclear and misleading financial promotions


A consumer credit firm was potentially misleading consumers by promoting that it offered lower and fairer loan rates when this may not be the case. The firm was promoting taking out a loan to pay off a credit card without warning consumers of the potential risks of taking out additional credit to pay off existing debt. The firm also did not make clear the existence of credit checks, its representative Annual Percentage Rate (APR) lacked prominence on some promotions, and it was using misleading statements that could not be substantiated.


Following our intervention, the firm withdrew non-compliant promotions and amended several promotions across multiple media platforms.

Unregulated crypto firm promoting illegally and not engaging


Despite our extensive attempts to contact a large overseas unregistered cryptoasset exchange, it refused to engage with us before the financial promotion regime came into force. The firm continued to issue financial promotions to UK consumers, including through its website, social media and apps after the regime came into force in October 2023.


We issued a consumer warning against the firm. We have worked with tech companies to remove and block the firm’s illegal financial promotions, resulting in the removal of the firm’s apps from UK app stores. As a result of our alert, an FCA regulated firm decided to suspend the provision of ‘on-ramp’ payment services, which allow the conversion of fiat currency into cryptoassets, to the exchange. We are working with international partners, including regulators in other jurisdictions, on co-operation and assistance in taking further action against the exchange.

Setting and testing higher standards

Peer-to-peer firm not robustly assessing the appropriateness of the product for customers


As part of our review into how new rules for high-risk investments had been implemented, we identified that a firm offering peer-to-peer investments had introduced an appropriateness assessment that was not compliant with our rules. The purpose of the appropriateness assessment is to objectively and fairly test whether an investment is appropriate for the customer. But the firm had weakened the effectiveness of the assessment by providing information relevant to the questions during the assessment process, informed customers of the questions they had incorrectly answered, included several binary questions, and re-used the same questions in subsequent assessments. This meant that some customers taken on may not have fully understood the risks of the products before investing.  


Following feedback to the firm it amended its appropriateness assessment to remove any guiding information, stopped informing customers which questions they answered incorrectly, reworked questions to include at least 3 plausible answers and introduced new questions for subsequent assessments.  


Firm offering qualifying cryptoassets had not identified webpages that constituted financial promotions


A firm offering qualifying cryptoassets included a ‘blog’ section on its website and had not identified that many of the articles in this section were financial promotions. As a result, these pages did not contain the required risk warnings. The website was also found to include promotions for products that were not available to UK based customers without prominent disclaimers, and the risk warning that the firm had implemented on the website was not suitably prominent.


Following our intervention, the firm amended the design of the risk warning to improve its prominence, removed access to pages of the products not available to UK based customers as well as introducing more prominent disclaimers where the products were referenced. The firm also blocked access to the 899 pages of the ‘blog’ section of its website and identified which articles were financial promotions and therefore required risk warnings.

Cryotoasset firm utilising affiliates for promoting its products


Many cryptoasset firms run ‘affiliate’ programmes where commission is paid to individuals or businesses who refer clients to the firm. Firms must have appropriate controls and oversight to ensure that their affiliates are not breaching financial promotions legislation. We identified a firm with no clear control framework to ensure any promotions made by its affiliates were legal.


Following our feedback, the firm updated its Affiliate Terms and Conditions to prohibit affiliates from referring UK-based consumers and introduced measures to reject any UK-based consumers who do get referred to the platform. Additionally, the firm has placed geolocation restrictions on its promotional materials provided to affiliates to prevent them being visible to UK consumers.

Promoting competition and positive change

Making ‘Buy Now Pay Later’ terms clearer

Following on from our earlier work on Buy Now, Pay Later (BNPL) providers we published a case study which highlighted the findings of our research where we shared that more than a quarter of UK adults used BNPL at least once in the 6 months to January 2023; with frequent users more likely to be in financial difficulty. This aims to continue to highlight the importance of consumers having enough information to know what they are taking on when using unregulated BNPL products and as a result prevent potential consumer harm.

How to report a misleading financial advert or potential scam

Report a financial advert or promotion that you think is misleading, unfair or unclear.

Report a scam, authorised firm or individual to us.

Our casework will usually involve confidential information for the purposes of section 348 of Financial Services and Markets Act 2000 (FSMA). We are therefore unlikely to be able to provide further information about particular cases. Find out more about the  information we can share.


  • The figures reported within this data are accurate at the time of publication. But 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. 


The data on this page is available under the terms of the Open Government Licence.