FCA consumer credit authorisation
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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.
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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.
The credit advertising rules under CONC 3 apply to any communication that is:
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.
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.
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.
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.
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.
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.
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.
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 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.
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.
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.
Search engine advertisements and comparison site listings that include rate information must include representative APR. The landing page must contain all triggered information prominently.
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.
Authoritative sources for credit advertising compliance.
FCA rules on credit advertising and financial promotions.
FCA HandbookStatutory requirements for credit advertisements.
legislation.gov.ukFCA guidance on complying with financial promotions rules.
Financial Conduct AuthorityExemptions and requirements for financial promotions.
legislation.gov.uk