Rules and ethics
Part of UK rules for finance creators in 2027, kept as five separate questions
Handing an approved finance creator ad to the publisher
Handing an approved finance creator ad to the publisher: the locked file, label records, edits that need fresh review and checks on the live item.
An approved finance ad can still go wrong between sign-off and the live post. The publisher, usually the creator or the agency that posts the content, holds final responsibility for the live item. The handover therefore needs a locked file, a record of labels and warnings, and a named person who can remove or correct it.
What to take away
- Hand the publisher one locked creative file and a record of required labels and warnings.
- State whether cropping, shortening, thumbnail changes or paid amplification need fresh review.
- Capture the live item as the audience sees it, including the surrounding caption and destination.
- Assign someone to remove or correct it if approval expires or a material claim changes.
- Stop if the commercial relationship, legal entity, approval path or evidence cannot be reconstructed.
Who holds the live item
The publisher holds final responsibility for the live item, even when the brand is the advertiser. In a creator-brand deal the publisher is usually the creator or the agency that posts the content, so the handover is addressed to them by name.
The marketer, creator, agency and publisher may each hold responsibilities that a private contract cannot erase. Ask every party to confirm its own task in writing rather than assuming the brand has completed all checks. A signed contract allocates the work; it does not transfer the duty.
What goes into the handover pack
The pack is one locked creative file plus the records that explain it. Each item answers a question the publisher would otherwise have to guess at, and each is tied to the exact audience, wording, images and date that were approved by the approver.
| Item | What it settles | Detail to record |
|---|---|---|
| Locked creative file | Which version is approved | One file, with no later edits |
| Labels and warnings | What must appear, and where | The ad label, any applicable product-specific risk warning and other required promotion information |
| Approval record | Who approved what | An approver named only if that firm approved this exact version |
| Re-review rules | Which edits need fresh review | Cropping, shortening, thumbnail changes and paid amplification |
| Removal owner | Who acts if approval expires or a claim changes | A named person with access to the live item |
| Recheck trigger | When claims and approvals lapse | An expiry date or event for each claim and approval |
The FCA's approver guidance explains that approving firms must be lawfully able to approve and must check the promotion against relevant rules. Confirming relevant FCA permissions belongs before the pack is built, not after the post is live.
Which edits need a fresh review
Any edit after approval can change what the audience understands, so state in advance which edits need fresh review. Cropping, shortening, thumbnail changes and paid amplification all alter the item the approver saw, and none should be treated as cosmetic.
Shortened cuts still have to present a balanced view of benefits and risks. FG24/1 explains that the financial promotion rules are technology neutral and apply across all channels used to advertise, including social media. A short cut that loses the warning needs the same scrutiny as the full version.
Preserve rejected drafts and reviewer comments so the team can see which wording was not approved and avoid restoring it during a later edit. Fixing a label alone will not repair an unsupported or unlawfully communicated financial claim. The correction has to go to the claim first, then to the label.
Check the live item as the audience sees it
Capture the live item exactly as the audience sees it, including the surrounding caption and the destination. The approved file proves what was sent, while only the capture proves what was published, and the two can differ. Store both together.
- Check that the label sits where people first encounter the endorsement, in wording that plainly identifies advertising.
- Follow every link through to the landing and purchase pages.
- Confirm that the label, price and important limitations stay consistent along the way.
- Check speech, captions, images, descriptions and small-screen layouts, and repeat the disclosure where parts can be viewed separately.
- Confirm that readers have a correction or complaint route.
The ASA's advice gives Ad at the start of a post as an example of clearly identifying advertising. Its current social-media advice warns that a biography disclosure may not be enough for individual posts, so the label belongs on the post itself.
When to remove or correct
Remove or correct the item when approval expires or a material claim changes, and name the person who does it before posting. The recheck trigger in the handover pack tells that person when to look, and the pre-release checks cover how to withdraw content fast.
Readers who spot a problem have three routes. Complain about an advertisement using the ASA's online complaints form. Report a suspected scam or unauthorised firm through the FCA's 'Report a scam or unauthorised firm' service. Report a business to the CMA through its service of that name; that route is for concerns, not individual consumer disputes.
Rehearse the failure before it happens. The incidents to rehearse show what a removal looks like in practice, and the five separate questions keep the advertising, promotion and data answers apart in the file, so a reviewer can see which one failed.
Before you act
- Confirm the locked file, labels and warnings are in the pack.
- Name the person who can remove or correct the live item.
- Capture the live item with its caption and destination.
- Set a recheck trigger for each claim and approval.
Common questions
Who is responsible for the live post?
The publisher holds final responsibility for the live item, usually the creator or the agency that posts it. The brand may be the advertiser, and a private contract cannot erase the responsibilities each party holds.
Does cropping or shortening an approved ad need a new review?
The handover should say so in advance. Cropping, shortening, thumbnail changes and paid amplification alter the item the approver saw, so the pack states whether each one goes back for fresh review.
What should be kept once the post is live?
The live item as the audience sees it, with its caption and destination, stored beside the locked file and the approval record. Preserve rejected drafts and reviewer comments too.
