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Consumer credit risk warnings and financial promotion restrictions
Representative APR requirements for credit advertising
How to advertise consumer credit products compliantly under FCA rules. Covers representative APR requirements, triggered information, social media advertising, risk warnings for high-cost credit, and the FCA financial promotions approval process.
Professional & Financial ServicesUK-wide
Every advertisement for a consumer credit product must comply with FCA
rules. This applies whether you are a lender advertising your own products,
a broker promoting finance options, or a retailer offering credit at the
point of sale. The rules apply to all channels: print, broadcast, online,
email, and social media.
Credit advertising is a frequent source of FCA enforcement action.
Non-compliant promotions can result in fines, required withdrawal of
advertising, and reputational damage. The FCA actively monitors credit
advertising, including social media, and takes a strict approach to
compliance.
When these rules apply
The credit advertising rules under CONC 3 apply to any communication
that is:
An invitation or inducement to engage in credit-related activity
Communicated in the course of business
Directed at consumers in the UK
This includes advertisements for loans, credit cards, hire purchase,
store credit, motor finance, and (from 15 July 2026) Buy Now Pay Later
products. It also covers communications from credit brokers promoting
the availability of credit.
How to create a compliant credit advertisement
Social media and digital advertising
Social media presents particular challenges for credit advertising
compliance. The FCA expects every individual post, tweet, or story to
be standalone compliant. You cannot rely on links to a full-terms page
to satisfy the triggered information requirements.
Character-limited platforms
On platforms with character limits (such as X, formerly Twitter), you
must still include all triggered information if a trigger is present.
In practice, this means either avoiding trigger language in short-form
posts or using the platform's native tools (such as image cards or
threads) to include all required information prominently.
Influencer marketing
If you pay influencers or affiliates to promote your credit products,
their posts are financial promotions and must comply with CONC 3. You
are responsible for ensuring their content is compliant before
publication. The FCA has taken enforcement action against firms whose
affiliate marketing did not meet credit advertising standards.
Pay-per-click and comparison sites
Search engine advertisements and comparison site listings that include
rate information must include representative APR. The landing page must
contain all triggered information prominently.
Common mistakes to avoid
Headline rate without representative APR:
Advertising '3.9% interest' without showing the representative APR
is a breach of CONC 3
Burying the APR: Showing a large '£99/month'
headline with a small representative APR in the footer fails the
prominence test
Stale representative APR: Not updating advertising
when your approval data shows fewer than 51% of customers receiving the
advertised rate
Missing risk warnings: Omitting the mandatory
HCSTC risk warning from payday loan advertising
Unapproved affiliate content: Allowing affiliates
or influencers to create credit promotions without FCA-approved sign-off
Social media shortcuts: Assuming a link to
'terms and conditions' satisfies triggered information requirements
on social media
0% offers without disclosure: Even 0% APR
offers trigger full disclosure requirements, because stating
any rate (including zero) is a trigger
What to do next
Review all current credit advertising against the requirements above.
Establish an approval workflow for all new promotions, and ensure
compliance sign-off is documented. If you use affiliates or intermediaries,
audit their content and put contractual obligations in place to ensure
ongoing compliance.
How to get FCA authorisation to offer consumer credit, including lending, credit broking, and debt collection. Covers application process, fees, responsible lending requirements, and high-cost credit rules.
What consumer credit regulation is, why it exists, and who it applies to. Covers the relationship between the Consumer Credit Act 1974, the Financial Services and Markets Act 2000, and the FCA's CONC sourcebook, including when FCA authorisation is required and when exemptions apply.
How the FCA Consumer Duty applies to consumer credit providers, brokers, and debt collectors. Explains the four outcomes for credit products, the annual board report requirement, how the Duty interacts with existing CONC rules, and current FCA supervisory priorities.
How to conduct, evidence, and document affordability assessments when lending to consumers. Covers the distinction between creditworthiness and affordability, income verification, expenditure analysis, proportionality, vulnerable customers, and the Consumer Duty overlay for credit products.
How to collect consumer debts compliantly under FCA rules. Covers CONC 7 requirements for arrears and default handling, forbearance obligations for customers in financial difficulty, default notice requirements, communication standards, vulnerable customer identification, and enforcement restrictions for improperly executed agreements.
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