Rules and ethics
Part of Finance influencers: what to send an approver before filming
Finance influencers: what to send an approver before filming
Finance influencers need an authorised firm to approve a promotion first. What to send, what each party keeps and when a changed post needs re-approval.
What to take away
- Treat a paid post that invites people to buy or invest as a financial promotion and get it approved first.
- Send the approver the final script, the caption and the on-screen text before filming wraps.
- Short-form video gets no discounta 20-second TikTok carries the same duty as a long blog post.
- A changed product, risk warning or call to action goes back for re-approval.
- Keep the approved version, the approval date and the approver's name with the published post.
When the approval request is yours to start
Approval is the creator's request to make, because Section 21 puts the restriction on whoever communicates the promotion. An unauthorised creator can communicate one where an authorised person has approved the content, and the Financial Services and Markets Act 2000 states that route.
Ask first whether the post is a promotion at all. Two tests do most of the work: is the content asking someone to take a financial step, and was it communicated as part of a business? A sponsored clip about a stocks and shares ISA clears both.
Is your post a promotion?
Does it invite or induce investment activity?
likely a financial promotion
outside the FCA perimeter
A creator describing their own budgeting, unpaid, usually fails the second test, though the advertising codes still apply. Check whether an exemption applies, such as financial journalism or some broadcast routes, and write down why the post sits outside the approval route.
What to send the approver
Send everything the audience will see or hear, in its final form. The approver signs off that content, so a script without the caption, or a caption without the on-screen text, leaves part of the post unapproved. Put it in front of the firm before filming wraps.
| Item | What to put in front of the approver | Back to the approver if it changes? |
|---|---|---|
| Final script | Everything said on camera | Yes, when the wording changes the product, warning or call to action |
| Caption | The text posted with the video, with its ad label | Yes, when it changes the product or call to action |
| On-screen text | Every word overlaid on the video | Yes, when it changes the product, warning or call to action |
| Product | The investment, credit or other product being promoted | Yes, always |
| Risk warning | The warning shown or spoken with the promotion | Yes, always |
| Call to action | What the audience is asked to do next | Yes, always |
The approver's own file matters as much as yours. The FCA tells approving firms to keep records, so a creator who keeps the same set of documents can answer a later question about what was approved without searching old messages.
Six steps from script to published post
Follow the route in order for every promotion. A 20-second TikTok carries the same duty as a long blog post, so the steps do not shrink with the clip, and each one leaves a document behind.
- Classify the post with the inducement and course of business tests, and note the answer.
- Check for an exemption. Financial journalism and some broadcast routes are carved out.
- If none fits, find an FCA-authorised firm willing to sign off the content.
- Send the final script, caption and on-screen text before filming wraps.
- Keep the approved version, the approval date and the name of the approver.
- Re-approve if the product, the risk warning or the call to action changes.
Section 21 approval route
- Decide if the post is a promotion
- Check whether an exemption applies
- Find an FCA-authorised firm to sign off
- Show final script, caption and on-screen text
- Keep approved version, date and approver
- Re-approve if product, warning or CTA changes
Responsibility does not transfer. A firm that approves content is signing off that content, and creators remain liable for what they publish, so the approval email belongs in the same folder as the finished post. Approval is not a licence to edit afterwards.
What each party keeps
Each party keeps a different document, and together they show who did what. The creator keeps the published post and the approval email, the brand keeps the brief and contract, and the approver keeps the signed-off version with its date.
| Who | Keeps | What it shows |
|---|---|---|
| Creator | Published post and approval email | The post matches the approved script |
| Brand | Brief, contract and approval record | Briefs were honest and approvals were checked |
| Authorised approver | Signed-off version and date | What was approved, and when |
| Platform | The paid partnership label as published | How the label appeared to the audience |
If a regulator asks later, that file is the whole defence. Brand teams can set the same expectation before contracts. Choosing Instagram money bloggers who already label ads correctly removes risk at source.
What FG24/1 says about unapproved posts
The FCA's finalised guidance on financial promotions on social media, FG24/1, was published in March 2024. It says unauthorised persons, such as social media influencers, who promote a regulated product without approval of an FCA-authorised person may be committing a criminal offence.
That sentence is why approval comes before filming rather than after the edit. The guidance also tells approving firms to keep records, so the file described above serves the creator and the approver alike. The quality checklist turns the record into a pre-publication check.
Common questions
When should the approver see the content?
Before filming wraps. The final script, caption and on-screen text go to the authorised firm first, so that the approval covers what is actually published and not an earlier draft.
What if the call to action changes after approval?
Re-approve. A change to the product, the risk warning or the call to action goes back to the approver, and the new approval date and version replace the old ones in the file.
Does a short video need the same approval as a long post?
Yes. Short-form video gets no discount, and a 20-second TikTok carries the same duty as a long blog post. The caption and on-screen text count as part of the content.
What should a creator keep on file?
The approved script, the approval date, the name of the approver and the published post with its ad label. If a regulator asks later, that file is the whole defence.
