Financial promotions are moving back to the top of the regulatory agenda.
For consumer credit lenders, brokers and introducers, 2026 is shaping up to be a year of increased scrutiny on how credit products are advertised, explained and distributed. The Financial Conduct Authority and Advertising Standards Authority are continuing to work closely together, and the direction of travel is clear: firms must be able to evidence that their promotions genuinely support informed customer decisions.
For many credit firms, this represents a shift from technical compliance towards outcome-focused marketing governance.
Promotions are now a conduct issue
Historically, financial promotions have often been viewed as a marketing compliance exercise — ensuring representative APRs are displayed correctly and risk warnings included where required.
That is no longer enough.
Under Consumer Duty, firms must ensure communications are clear, fair and support good customer outcomes. This means regulators are looking beyond wording and into how promotions shape customer understanding and behaviour.
Key areas of focus now include:
- whether headline claims create unrealistic expectations,
- whether eligibility and affordability are presented clearly,
- and whether customers fully understand the nature and cost of credit being offered.
If promotions drive applications from customers who are unlikely to be eligible or able to afford the product, regulators will question whether those communications are delivering fair outcomes.
Broker and introducer activity remains a risk area
For lenders relying on brokers, affiliates or introducers, oversight of third-party promotions is a continuing challenge.
The FCA has repeatedly emphasised that authorised firms remain responsible for promotions issued on their behalf. Where brokers or lead generators use their own advertising or landing pages, lenders must still ensure those communications meet regulatory standards.
This creates particular risk in high-volume digital channels where messaging can evolve quickly and oversight may be inconsistent.
Regular monitoring, approval frameworks and clear contractual expectations are now essential. Passive reliance on introducer compliance is unlikely to satisfy supervisory expectations.
Digital channels under scrutiny
Social media, search advertising and comparison platforms continue to attract regulatory attention.
Common issues identified by regulators include:
- “guaranteed acceptance” or similar claims,
- insufficient prominence of risk information,
- unclear identification of the regulated firm, and
- promotions that blur the line between soft eligibility checks and full applications.
These risks are amplified where speed and conversion are prioritised over clarity. Under Consumer Duty, firms must be able to demonstrate that their communications support informed decision-making rather than simply driving volume.
Why firms should act now
Financial promotions often evolve incrementally. New campaigns are launched, affiliates onboarded and messaging refined over time. Without structured oversight, this can create gradual drift away from compliant and balanced communications.
A proactive review of promotions across all channels, including broker and affiliate activity, can significantly reduce regulatory risk.
Firms should be confident that:
- approval processes are robust and documented,
- promotions reflect actual product terms and eligibility, and
- management information identifies trends in complaints or misunderstandings linked to advertising.
Waiting for regulatory queries or complaints to highlight weaknesses is a far less comfortable position.
How ALPH Legal & Compliance Can Support
ALPH Legal & Compliance works with consumer credit firms to strengthen financial promotions governance and ensure communications align with FCA and ASA expectations.
Our support includes:
- independent financial promotions and marketing audits,
- introducer and affiliate oversight reviews,
- Consumer Duty alignment assessments across customer communications, and
- development of robust approval and monitoring frameworks.
As scrutiny of credit advertising continues to increase, firms that treat financial promotions as a core conduct risk — rather than a marketing afterthought — will be best placed to manage regulatory expectations and maintain customer trust.
To discuss how ALPH can support your firm in reviewing and strengthening its financial promotions framework, get in touch directly.