Finfluencers - 5 top tips to ensure your financial promotions are compliant

In a world where a 15-second TikTok can move markets and a YouTube video can influence thousands of investment decisions, the landscape of financial promotions is evolving rapidly. For FinTechs, the rise of the finfluencer - a social media influencer promoting financial products or advice - presents both a powerful marketing opportunity and a growing compliance minefield.

The FCA is sharpening its focus on the role of online promotions, making it time for Fintechs to reassess how they engage with digital content creators and ensure their marketing strategies remain on the right side of regulation.

The FCA is upping its game…

If it walks, talks, and acts like a financial promotion, it’s subject to the rules, as far as the FCA is concerned.

In 2024 and 2025, the FCA has:

• Issued guidance and warnings to firms about working with influencers

• Removed non-compliant promotions and launched investigations

• Supported the Treasury Committee's inquiry into finfluencers, which aims to assess the impact of social media on consumer behaviour and market integrity

  
  

Influencers and the risks for FinTechs…

Partnering with finfluencers makes you accountable for ensuring that any promotional content meets FCA standards, including:

• Being clear, fair and not misleading

• Including mandatory risk warnings

• Being approved by an authorised person, if you're not already regulated

Not complying with the FCA’s rules could land you with:

• Enforcement action

• Reputational damage

• Consumer harm (and redress obligations)

  
  

Practical tips to stay compliant…

You can stay compliant while still leveraging the reach of finfluencers:

1. Know What Counts as a Financial Promotion

Even casual product mentions, referral codes, or endorsement posts can qualify.

2. Use Authorised Approvers

If you're not an FCA-authorised firm, ensure any financial promotions are approved by an authorised entity under Section 21 of the Financial Services and Markets Act 2000.

3. Train and Monitor Influencers

Brief influencers on your expectations, provide clear disclosures, and monitor the content they publish. Document your oversight.

4. Include Risk Warnings & T&Cs

Ensure all posts contain appropriate risk warnings, and link to full terms and disclosures.

5. Be Transparent About Incentives

Make sure influencers disclose if they’re being paid or incentivised to promote your products.

If in doubt, give us a shout…

Don’t wait for the regulator to come knocking - we can review your finfluencer strategy and assist you to ensure it aligns with the FCA's latest expectations. What are you waiting for, get in touch with our compliance team today.

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