The golden rule: clear, fair and not misleading
Every financial promotion you make must be clear, fair and not misleading. That's the overarching standard everything else sits beneath, and the FCA has been explicit that it isn't going away. If a promotion could give a customer the wrong impression about cost, availability or your role, it fails — however technically accurate the small print is.
When you need a "representative example"
If your promotion mentions the cost of credit or an interest rate — for example "£199 a month" or "9.9% APR" — you generally must include a representative example. That's a standard set of details (the rate, the amount of credit, the instalments, the total amount payable and a representative APR) presented together. The main exception is a genuine 0% APR interest-free offer, shown as such, which doesn't trigger the full example.
When you need a "representative APR"
Even without quoting a rate, certain things trigger a representative APR: an incentive to apply for credit, a favourable comparison, a "triggering statement" (for instance, suggesting credit is available to people who might otherwise struggle to get it), or even a name or logo that implies something about cost. A representative APR is written as a figure followed by "% APR Representative", quoted to one decimal place.
Prominence matters
Where a trigger applies, the representative example or APR must be given no less prominence than the thing that triggered it. In plain terms: you can't have "£199 a month" in big letters and bury the APR in the footnotes.
Be clear about your role and commission
As a credit broker you should make clear that you introduce customers to a lender rather than lending yourself, and disclose that you may receive commission. This dovetails with the Consumer Duty's consumer-understanding outcome — customers should genuinely understand what they're agreeing to.
It applies across every channel
These rules apply equally to your website, social media posts, emails and in-showroom materials. A finance offer in an Instagram post is a financial promotion just as much as one in a brochure.
Two important caveats: the FCA is currently reviewing the financial promotion rules in CONC 3 (its 2026 consultation), so some specifics may change — and because the detail is genuinely fiddly, it's worth having promotions checked by someone with compliance experience before they go live. This guide is a summary, not advice.
Our application pack includes a financial promotions policy that sets out how your firm keeps its advertising compliant — one of the documents the FCA expects to see.