UK’s FCA FG24/1: Finalised guidance on financial promotions on social media
March 27, 2024
UK’s FCA FG24/1: Finalised guidance on financial promotions on social mediaMarch 27, 2024 The FCA has set out its expectations for firms and others, including influencers, using social media to communicate financial promotions Why should I read this?It is well established that any financial promotion needs to be fair, clear and not misleading and support consumer understanding. FG24/1 “Finalised guidance on financial promotions on social media” (the “Guidance”) published by the FCA on Tuesday 26 March provides additional guidance on what this means when firms publish financial promotions on social media. It is important when considering the use of social media to promote financial products to remember that the FCA’s rules on financial promotions are ‘tech neutral’; in other words they are not tailored to the medium in which they are delivered, such as social media. The Guidance does not introduce new obligations, but rather seeks to bridge that gap by indicating how firms might comply with the existing obligations. It does this by highlighting the obligations which are relevant in a social media context, when social media content might constitute a regulated financial promotion and, importantly, who is responsible for such content. The Guidance also sets out examples of good and bad practice. The FCA first published guidance on the use of social media to communicate with customers back in 2015. The fact that that guidance started with the Oxford Dictionary definition of ‘social media’ shows how much has changed and how necessary it was for that guidance to be updated to reflect current practice and the rise of the influencer, as well as regulatory developments in the interim, most significantly the introduction of the Consumer Duty. Indeed, influencers now have their own chapter in the Guidance. The Guidance should not be thought of as a one-stop-shop because there are requirements and additional pieces of guidance for specific types of promotion (for example, there are already numerous FCA publications relating to cryptoasset promotion), but it does cross-reference these and should serve as a helpful first resource for those firms and individuals promoting financial products on social media. What practical steps should I take on making financial promotions on social media?The Guidance has practical implications for both firms and individual influencers. Authorised firms communicating or approving financial promotions on social media must bear the following in mind:
Influencers and unauthorised persons communicating financial promotions on social media need to be aware of the following:
What else do I need to know about financial promotions on social mediaThe FCA has re-confirmed the broad scope of the financial promotion regime. While the Guidance does not contain any new substance, it should provide firms with some helpful real world examples of how to comply with the existing rules. It serves to underline how unsuitable some social media platforms may be for certain, especially complex, products. It also highlights the risks social media influencers can run by posting content about financial products and services if they do not conform strictly to parameters laid down by an appropriate authorised firm. See our previous client briefings
How Eversheds Sutherland can helpWe provide guidance to authorised individuals regarding financial promotions regulations and how to fulfil the necessary criteria when granting approvals for financial promotions by unauthorised parties, both in specific cases and within the broader context of financial services regulation. Thank you to Tim Fosh for co-writing this article. Latest Insights
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