Guide
Comply with credit advertising rules
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.
You must show the representative APR in credit adverts if you mention interest rates, charges or credit costs. The APR must be clear and apply to at least 51% of customers. Include all required information and get adverts approved before publishing.
- Show representative APR if advert mentions rates, charges or credit costs
- APR must apply to at least 51% of successful customers
- Include all required information like total credit amount and repayments
- Make APR more prominent than other rates in the advert
- Follow rules for all adverts including social media
- Add risk warnings for high-cost or secured credit
- Get adverts approved by an FCA-authorised person before publishing
- Keep records proving your APR meets the 51% rule
- Fines for breaking rules can include withdrawing adverts
- Rules apply to loans, credit cards, hire purchase and store credit
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
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1. Determine whether your advertisement triggers APR disclosure
If your advertisement includes any of the following, you must also show the representative APR: an interest rate (including 0%), the amount of any payment, the number of payments, the period of an agreement, or any statement about the cost of credit. Even a phrase like 'low-rate finance available' is a trigger. If your advertisement mentions none of these and simply states that credit is available, you are not required to show the representative APR, but you must still ensure the promotion is fair, clear, and not misleading.
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2. Include all required triggered information
When any trigger is present, your advertisement must include: the representative APR (not just the headline rate), the type of credit (e.g. personal loan, hire purchase), the cash price of any goods or services (if applicable), the total amount of credit, the duration of the agreement, the total amount payable, and the amount of each repayment. All of this information must be presented together, with equal prominence. You cannot bury the APR in footnotes while highlighting a low monthly payment.
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3. Apply the 51% rule correctly
The representative APR you advertise must be the rate at which you reasonably expect at least 51% of customers responding to the advertisement to receive. If you advertise 9.9% APR representative, at least 51% of successful applicants must actually get 9.9% APR or better. You must keep records demonstrating ongoing compliance with this threshold. If your approval data shows the rate drifting above 51%, you must adjust the representative APR in your advertising.
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4. Ensure prominence and clarity
The representative APR must be more prominent than any other rate or payment information in the advertisement. It should be at least as large as and no less prominent than the trigger that required its inclusion. Avoid visual tricks that draw the eye away from the APR towards a headline monthly payment figure. The FCA considers the overall impression of the advertisement, not just technical compliance with layout rules.
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5. Apply risk warnings where required
Certain credit products require specific risk warnings in all advertising. High-cost short-term credit (HCSTC) advertisements must include a mandatory risk warning. Secured lending must carry a 'your home may be repossessed' warning. Check the current CONC 3 requirements for your specific product type.
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6. Get financial promotions approved before publication
Under section 21 of FSMA, financial promotions must be approved by an FCA-authorised person before they are communicated. If your firm is FCA-authorised, you can approve your own promotions (ensure a compliance-approved sign-off process exists). If you are not authorised, an authorised firm must approve the promotion. Since February 2024, the FCA has required authorised firms that approve third-party promotions to be on the s21 approver register.
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7. Keep records and monitor compliance
Retain copies of all financial promotions and records of approval for at least the period they are in use plus 12 months. Monitor the 51% threshold for representative APR on an ongoing basis. Review advertisements periodically and when rates or terms change.
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.
- For pre-contract information requirements, see Meet pre-contract disclosure requirements
- For FCA authorisation, see FCA consumer credit authorisation