Financial services
FCA rules for a firm's website: financial promotions, the Consumer Duty and what compliance strikes out
For an FCA-authorised firm, every page of the website is a communication, and the core rule is that it must be "fair, clear and not misleading" (COBS 4.2.1R). Where capital is at risk, the page must say so. The Consumer Duty adds that customers should be able to understand what they are buying. In practice that means plain claims, prominent fees and risks, and FCA details that match the Register.
This is a practical guide for marketing, not legal advice. Your compliance officer or network has the final word.
Does the FCA regulate a firm's website?
It regulates what the firm communicates, and the website is one of the biggest communications a firm has. The rule in COBS 4.2.1R is that "a firm must ensure that a communication or a financial promotion is fair, clear and not misleading" (FCA Handbook, COBS 4.2). The guidance alongside it says the rule applies in a way that is proportionate to the means of communication, so a web page is judged as a web page.
That covers the homepage, service pages, blog posts, case studies and anything the firm publishes that might lead someone to use its services. A blog post about pensions is still a communication from a regulated firm.
What does "fair, clear and not misleading" mean on a web page?
In plain terms: the page does not claim more than you can deliver, it does not hide the drawbacks, and a reasonable reader comes away with an accurate picture. COBS 4.2 also says that if a product or service puts a client's capital at risk, the communication must make that clear. Where a feature is described as "guaranteed", "protected" or "secure", the firm must give the information needed with sufficient clarity and prominence.
On a website, prominence is about placement. A risk warning in grey text in the footer, far below the claim it qualifies, is unlikely to meet the standard. Put the balance next to the claim it balances.
What does the Consumer Duty add?
The Consumer Duty sets a higher standard for firms dealing with retail customers. One of its outcomes is consumer understanding: communications should help customers make informed decisions. For a website, that pushes towards plain English, fees stated up front, and explanations a customer can follow without phoning.
This is where compliance and search line up. Plain, specific pages that answer the customer's question are what the Consumer Duty asks for, and they are also what search engines and AI assistants prefer to quote.
What does compliance most often strike out?
| Usually rejected | Why | Write instead |
|---|---|---|
| "We'll get you the best deal" | An outcome you cannot guarantee | What you compare, and how many lenders or providers you can access |
| "Grow your wealth safely" | Implies no risk where capital is at risk | What the service aims to do, with the risk stated beside it |
| "Guaranteed approval" | Misleading; lenders decide | The kinds of case you help with |
| "No fees" | Often untrue once commission or product charges are counted | How you are paid, in a sentence |
| Past returns as a headline | Past performance is not a reliable guide | Your process, with any figures properly balanced |
| Unnamed client testimonials with outcomes | Can imply typical results | Testimonials your compliance team has approved, about service |
Why should the website match the FCA Register exactly?
Because the FCA tells consumers to check. It advises people to check a firm on its Register before using it, and to make sure the contact details they have been given match the Register, since clone firms copy genuine ones (FCA, how to check a firm).
Show your firm reference number on every page, link to your Register entry, and keep the name, address, phone and web address identical across the site, the Register and your Google Business Profile. If you are an appointed representative, say who your principal is. A careful client should be able to check you in under a minute.
How should a regulated firm run website changes?
As a short, written process: draft, compliance review, approval recorded, then publish. Keep a dated copy of each approved page. If your site runs on a system where anyone can change copy without review, that is a risk worth fixing, and it is usually a small change to the workflow rather than a new website.
We build sites for FCA-regulated firms with compliance sign-off built into the timeline. See websites for FCA-regulated firms for how we work, and our guides to SEO for financial advisers and SEO for mortgage brokers. For regulated professions more widely, read websites for regulated firms.
Questions about FCA rules and websites
Do FCA financial promotion rules apply to websites?
Yes. COBS 4.2.1R requires a firm to ensure that a communication or financial promotion is fair, clear and not misleading, and a website is a communication. The rule applies proportionately to the medium, so each page is judged as a web page.
Where should risk warnings go on a website?
Next to the claim they balance, with enough prominence to be read. COBS 4.2 requires firms to make it clear where capital is at risk, and a warning hidden in a distant footer is unlikely to meet that standard.
Does the Consumer Duty affect website copy?
Yes. One of its outcomes is consumer understanding, which pushes firms towards plain English, fees stated clearly and explanations customers can follow without phoning.
Should an FCA-regulated firm show its reference number on its website?
Yes. The FCA tells consumers to check firms on its Register and to make sure contact details match, because clone firms copy genuine ones. Showing the reference number with a Register link on every page makes that check easy.