Financial Conduct Authority - Alex Genn Copywriting

What the FCA’s 2026 insurance regulatory priorities mean for your marketing content

Alex Genn — Mon, 20 Apr 2026 09:01:09 +0000

Is your insurance marketing keeping pace with what the FCA actually expects from firms right now?

If you haven’t read the regulator’s brand new Regulatory Priorities report for insurance, published in February 2026, now’s the time. Because what it says has real implications for how you communicate with customers, and the cost of getting it wrong is significant.

This blog breaks down the four priority areas, what the FCA expects from firms and, crucially, what all of this means for your content and communications. Whether you’re a marketing director, a compliance-aware CMO or a sustainability officer trying to align your messaging with a fast-changing regulatory environment, read on.

Why this report matters

The FCA’s insurance priorities report is the regulator’s clearest signal yet about where it’s pointing its supervisory lens. It replaces more than 40 portfolio letters (the FCA’s words, not ours) and is designed to be read by boards and chief executives as a guide to action.

The report covers retail insurers, wholesale insurers, insurance intermediaries, price comparison websites, life insurers and funeral plan providers. In other words, if you work in or around the insurance sector, this is directly relevant to you.

The four headline priorities for 2026 are:

Improving consumer understanding, claims handling and service quality
Increasing access to insurance
Supporting growth and innovation
Simplifying regulation

Let’s take each one in turn.

Priority 1: Consumer understanding, claims handling and service quality

This is where the FCA is focusing its sharpest attention, and it’s the area with the most direct implications for your content.

The report is unambiguous: “too many people have poor experiences when they make a claim.” Following a Which? super complaint on home and travel insurance, the FCA has committed to continuing supervisory and enforcement investigations into claims handling, and is actively reviewing how firms communicate cover to consumers.

The regulator expects firms to:

Be clear. Tell consumers what their insurance covers and actively test whether they’ve understood it.
Handle claims fairly. Respond promptly, fairly and transparently.
Track outcomes. Monitor whether products and interactions are delivering good consumer outcomes in line with rules.

That last point is critical for marketers. It’s not enough to write good copy at point of sale and forget about it. The FCA wants firms to check this continually: that their communications are doing what they’re supposed to do. That means your product descriptions, policy summaries, FAQs, renewal letters and claims communications all need to be working together, and all need to be tested against real consumer understanding.

The report also flags that the FCA’s Motor Total Loss claims work will result in around 270,000 drivers receiving compensation. It’s a powerful reminder of what happens when consumer communications fall short.

What this means for your content

Every piece of consumer-facing content needs to pass a ‘would a real person understand this?’ test. That includes your website copy, your email journeys, your renewal notices and your claims guidance. Jargon-heavy, passive-voice policy language doesn’t just frustrate customers. Under Consumer Duty, it can constitute a failure to deliver good outcomes.

Priority 2: Increasing access to insurance

The FCA’s report highlights a sobering reality: some of the most vulnerable people in society can’t access insurance at all. The regulator is working with the Government’s Financial Inclusion Strategy and the Motor Insurance Taskforce to address this, and firms are expected to engage with both documents and consider where they can make improvements.

Specific areas of focus include:

Increasing home contents insurance uptake for social renters
Travel insurance underwriting for people with pre-existing mental health conditions
Premium finance. The FCA’s market study found the cost of paying for insurance monthly has fallen since 2022, saving consumers an estimated £157 million annually. Firms are expected to continue Fair Value Assessments and address any areas that don’t give consumers fair value.

What this means for your content

If your firm serves or wants to serve customers in vulnerable circumstances, your content strategy needs to reflect that. This isn’t about adding a vulnerable customer policy to your website footer. It’s about designing communications that genuinely work for people who may be anxious, digitally excluded or dealing with complex needs. Plain language, accessible formats and inclusive design aren’t nice-to-haves. Under the Consumer Duty, they’re expected.

At Alex Genn Copywriting, our specialist financial services writers have over 20 years’ experience, with global brands, SMEs and disruptive startups. Get in touch today to discuss your requirements.

Priority 3: Supporting growth and innovation, especially AI

This section of the report is forward-looking, and it’s genuinely interesting. The FCA wants a growing, innovative insurance market, and it explicitly encourages firms to experiment with AI. But there’s a clear caveat: they must monitor consumer outcomes closely.

The FCA is:

Evaluating the risks and opportunities of AI in insurance (underwriting, claims, consumer services)
Reviewing the cyber insurance market
Consulting, with the PRA, on a new regulatory framework for captive insurance

The regulator points firms toward its AI Lab and Regulatory Sandbox as places to test ideas safely.

What this means for your content

If your firm is using or planning to use AI in its consumer-facing communications (chatbots, automated correspondence, AI-generated policy summaries) you need a clear governance framework for that content. Who’s checking the outputs? How are you testing for accuracy and clarity? The FCA’s message is that innovation is welcome, but responsibility for consumer outcomes stays with the firm.

This is also a moment to think about your thought leadership content. Cyber insurance is a growing market, and firms that can communicate clearly about complex risks, in plain English, to business owners who don’t necessarily have a risk background, have a real commercial opportunity.

Priority 4: Simplifying regulation

The FCA is actively working to simplify its insurance rulebook. In December 2025 it published PS25/21: Simplifying the insurance rules, and further consultations are underway covering everything from GAP insurance rules to General Insurance Pricing data and information disclosure requirements.

The direction of travel is towards relying more on the Consumer Duty as a principles-based framework, rather than stacking up product-specific rules. For firms, this means greater flexibility but also greater responsibility to demonstrate that their approach is genuinely delivering good outcomes.

What this means for your content

Fewer prescriptive rules doesn’t mean less scrutiny. In fact, a principles-based framework puts more pressure on firms to show their working, to demonstrate through their communications and their data that they’re genuinely serving their customers well. Your content needs to reflect not just what you’re legally required to say, but what a well-run firm would want to say.

The Consumer Duty thread running through all of this

It’s worth stepping back and noticing that Consumer Duty underpins all four of the FCA’s 2026 priorities. The report makes this explicit: “We will continue our work to ensure the Consumer Duty is integral to how regulated financial firms treat their consumers.”

The four outcomes under Consumer Duty (products and services, price and value, consumer understanding and consumer support) aren’t just compliance checkboxes. They’re a framework for how firms should think about every customer interaction, including every piece of content they produce.

If you’re not already thinking about your content through a Consumer Duty lens, 2026 is the year to start. The FCA has been clear that where it identifies serious misconduct, it will act, including through enforcement.

A quick compliance content checklist

Here’s a practical starting point for reviewing your insurance communications against the FCA’s 2026 priorities:

Consumer understanding

Does your policy summary explain, in plain English, what is and isn’t covered?
Are your exclusions clearly signposted rather than buried in small print?
Do you test your communications with real consumers, not just pass them through legal review?

Claims communications

Is your claims process explained clearly and proactively, not just when things go wrong?
Do your claims communications set realistic expectations about timelines?
Are vulnerable customer needs considered at every stage of the claims journey?

Access and fair value

Are your communications accessible to people with disabilities or low literacy?
Do your renewal communications make it easy for customers to understand what they’re paying and why?
If you offer premium finance, are you transparent about the cost?

AI and emerging tech

If you’re using AI to generate or personalise content, who is responsible for quality-checking the outputs?
Do you have a process for identifying and correcting AI-generated errors before they reach customers?

Why specialist financial services copywriting matters more than ever

Most marketing teams understand their products but writing about financial products in a way that’s clear, accurate, engaging and compliant is genuinely difficult. It requires a deep understanding of the regulatory landscape, an ability to translate complex concepts into plain English, and the experience to know where the lines are.

Generic copywriters (and, increasingly, AI tools used without proper oversight) can produce content that sounds fine but falls short of Consumer Duty standards. That’s not a theoretical risk. The FCA is actively reviewing firms’ communications, and the Which? super complaint response shows it’s prepared to act.

At Alex Genn Copywriting we’ve been working with global financial services brands, SMEs and startups for over twenty years, ensuring their content works harder for them while staying compliant. Our client experience includes American Express, Invesco, Lloyds Banking Group, Rathbones, Miller Insurance, Atradius, Moody’s Analytics, Bank of Scotland, NatWest, Ecclesiastical and AXA, among many others. View some examples of our financial services work.

We understand the FCA’s Consumer Duty framework, the nuances of insurance communications and the difference between content that merely complies and content that genuinely serves your customers. Talk to us today to find out how we can help.

What happens next

The FCA’s timeline for 2026 is busy. Key milestones include:

Q1 2026: Analysis of how different sales processes affect consumer outcomes begins; AI review of the insurance sector gets underway; travel insurance underwriting review for customers with pre-existing mental health conditions launches
Q2 2026: Review of how home and travel insurance firms are improving consumer understanding of their cover
Q3 2026: Pure Protection Market Study final report published
Q4 2026: Value measures rules review concludes

That means the pressure on firms to demonstrate good consumer outcomes, through their communications, their data and their processes, is only going to increase throughout the year. Getting your content right now, rather than scrambling to catch up later, is the wise move.

Ready to make your insurance content work harder?

The FCA’s 2026 insurance priorities are a clear signal: consumer communications are under scrutiny, and firms that can’t demonstrate genuine clarity and fair dealing face real regulatory risk.

At Alex Genn Copywriting, we’ve spent over two decades helping financial services brands get their words right, from policy documents and website copy to thought leadership and annual reports.

If you want insurance content that’s clear, compliant and actually connects with your customers, we’d love to talk.

The post What the FCA’s 2026 insurance regulatory priorities mean for your marketing content appeared first on Alex Genn Copywriting.

How to manage financial promotions approval without slowing down marketing

Alex Genn — Wed, 15 Apr 2026 14:06:47 +0000

The challenge: balancing compliance and speed

For most marketing teams in financial services, compliance is seen as a necessary constraint.

Campaigns need to move quickly, but every piece of content must be reviewed, approved and documented. This often creates tension between marketing and compliance, particularly when timelines are tight.

The assumption is that faster marketing increases risk, while stronger compliance slows everything down.

The FCA’s expectations suggest a different approach. Under Consumer Duty, firms are expected to have governance processes that support good outcomes without introducing unnecessary friction. In other words, compliance should enable effective communication, not hinder it.

Quick answer: what effective FCA governance looks like

Effective governance isn’t just about control. It’s about creating a system where:

– Roles and responsibilities are clearly defined

– Content is developed with compliance in mind from the outset

– Approval processes are structured and consistent

– Decisions are documented and evidence-based

When these elements are in place, marketing can move quickly without compromising on compliance.

Why approval processes often fail

In practice, many approval processes become inefficient over time. Content is passed back and forth between teams, feedback is repeated across multiple projects and timelines begin to slip.

While this is often attributed to compliance requirements, the root cause is usually earlier in the process. We often see content reach compliance teams in a form that needs serious reworking. This includes unclear structure, imbalanced messaging and missing or poorly presented risk information

The result of this is that compliance teams are forced to focus on fundamental issues rather than final checks. That’s not where they should be spending their time and it creates delays that can be easily avoided

Where efficiency really comes from

One consistent pattern is that approval processes become significantly more efficient when content is written with FCA expectations in mind from the start.

Instead of multiple rounds of revision, feedback becomes more focused and approvals are faster.

This doesn’t mean you need to make major changes to governance structures. It just requires a shift in how you develop your content.

At Alex Genn Copywriting, we provide specialist financial services writers with over 20 years’ experience. Get in touch today to discuss your requirements.

Where is your bottleneck?

If your approval process feels slow or unpredictable, it’s worth identifying where the delays occur. Consider some of the following:

– Does compliance feedback focus on structure and clarity rather than detail?

– Are similar issues raised repeatedly across different pieces of content?

– Do timelines vary significantly from project to project?

If the answer to any of these is yes, the issue may lie in the content itself rather than the approval process.

A practical framework for efficient FCA compliance

Improving approval processes starts with clarity and consistency. The following principles provide a practical foundation.

Clarity

You must have clear roles and responsibilities. Everyone involved in the process should understand, who is responsible for drafting content, who reviews it and who has final sign-off authority

The FCA has highlighted unclear accountability as a common issue, particularly in larger organisations. And if you think about it, that makes sense. If roles aren’t clearly defined, delays and inconsistencies become more likely.

Consistency

Consistency reduces complexity. Using standard templates, guidelines and frameworks can make sure your content meets baseline expectations before it reaches compliance. This allows compliance teams to focus on higher-level considerations rather than correcting avoidable issues.

It might not happen immediately but over time, this significantly improves efficiency.

Collaboration

One of the most effective ways to reduce delays is to get compliance involved in the process much earlier. Now, don’t worry, that doesn’t mean reviewing every draft in minute detail. But it does mean you’ll be more closely aligned on key principles and expectations, upfront.

When marketing and compliance teams work together from the start, the number of revisions required later is reduced. This creates a more predictable and efficient workflow. And it will save you time in the long run.

Evidence

Under Consumer Duty, firms are expected to demonstrate that their processes support good outcomes. This means maintaining clear records of:

– Decisions made

– Changes implemented

– Rationale for those changes

While this may seem like an additional burden, it can actually streamline future approvals by providing a clear reference point.

The crucial elements for Consumer Duty

Recent guidance places strong emphasis on governance and oversight.

You must be able to show not only that content is compliant, but that the processes behind it are robust, consistent and focused on customer outcomes.

Inefficient approval processes can undermine this by introducing delays, inconsistencies and unnecessary complexity. By contrast, a well-structured process supports both compliance and performance.

FAQs on FCA compliance

What does the FCA expect from governance processes?

The FCA expects firms to have clear, structured and well-documented processes for creating and approving financial promotions. These processes should support good customer outcomes and allow firms to demonstrate how decisions are made.

What role does documentation play in FCA compliance?

Documentation is essential under Consumer Duty. Firms are expected to maintain records of decisions, changes and rationale to demonstrate that their processes support customer understanding and good outcomes. This also helps streamline future approvals by providing a clear reference point.

Why do financial promotions approval processes slow down?

Approval processes often slow down because content reaches compliance teams in an incomplete or unclear state. Common issues include poor structure, missing risk information and inconsistent messaging, all of which require significant rework. Improving content upfront can significantly reduce delays.

How can marketing teams speed up FCA approvals?

Marketing teams can speed up approvals by:

– Building compliance considerations into the writing process

– Using clear templates and guidelines

– Aligning with compliance teams early

– Ensuring content is structured and balanced before submission

This reduces the need for multiple revision cycles.

Who is responsible for approving financial promotions?

An authorised individual within the firm must sign off financial promotions.

Can governance processes be flexible?

Yes. The FCA recognises that approaches should be proportionate to the size and complexity of the firm.

How can marketing teams speed up approvals?

By ensuring content is clear, structured and aligned with FCA expectations before it reaches compliance.

Looking for support?

Efficient compliance isn’t about removing checks. It’s about improving how content is created and reviewed.

At Alex Genn Copywriting, we help financial services firms produce FCA-compliant content that moves smoothly through approval processes, reducing delays and improving outcomes. Our 25 senior-level copywriters collaborate closely with your team, sharing their expertise and creativity, to guarantee a compliant, effective project.

Get in touch to discuss how we can support your team.

The post How to manage financial promotions approval without slowing down marketing appeared first on Alex Genn Copywriting.

Designing customer journeys that meet FCA expectations

Alex Genn — Sun, 12 Apr 2026 10:08:43 +0000

Why the FCA focuses on journeys, not just individual content

Most marketing teams naturally think in terms of individual assets.

A landing page. An email. A brochure.

Each piece is created, reviewed and approved on its own terms. But from a regulatory perspective, this is only part of the picture.

The FCA has made it clear that customer understanding is shaped by the entire journey, not just isolated communications. Under Consumer Duty, businesses are expected to consider how information is presented, repeated and reinforced over time, and whether that overall experience enables customers to make informed decisions.

This represents a shift in responsibility. It is no longer enough for individual pieces of content to be compliant in isolation. They must work together as part of a coherent, structured journey.

Quick answer: what makes a customer journey FCA-compliant

A compliant customer journey is one that actively supports understanding from start to finish.

This means that communications should not simply exist as standalone touchpoints. Instead, they should guide customers through a logical progression, where each interaction builds on the last.

In practice, this involves:

– Introducing key concepts early and reinforcing them over time

– Presenting information in manageable stages rather than all at once

– Ensuring consistency across channels and formats

– Making it easy for customers to revisit and compare information

When these elements are missing, even well-written content can fail to meet FCA expectations.

Where customer journeys typically break down

In many organisations, content is created in silos. Different teams are responsible for different channels, and while each piece may be reviewed individually, there is often limited coordination across the full journey. Over time, this leads to a fragmented experience.

As a result, your customers may encounter:

– Slightly different explanations of the same product

– Inconsistent emphasis on risks and benefits

– Gaps in information at key decision points

The FCA highlights that firms should not assume customers will piece together information themselves. If the journey is not designed intentionally, misunderstandings become far more likely.

This is where risk begins to build, often in ways that are not immediately visible internally.

Our insight: why journeys fail in practice

At Alex Genn Copywriting, we regularly work with firms that have strong individual content but weak overall journeys.

The issue is rarely a lack of effort. In fact, many organisations produce a high volume of content across multiple channels.

The problem is that this content has not been designed to work together.

Without a clear structure, important messages are diluted, repeated inconsistently or introduced too late in the process. From a regulatory perspective, this makes it harder to demonstrate that customers are being supported effectively.

From objective and audience understanding, through to information hierarchy, core messaging and final content, our senior-level writers have the experience to deliver a coherent, consistent, effective customer journey.

Does your content work as a journey?

A useful way to assess this is to step back and look at the full experience from a customer’s perspective. This is a particular skill and it takes a little time to master. Really imagine yourself in their shoes, think about what they’re looking for, what’s important to them and what might be a barrier to understanding.

Ask yourself:

– What does a customer see first?

– What do they see next?

– How does each interaction build on the previous one?

If the answers are unclear, or if different parts of the journey feel disconnected, there is a strong chance that the overall experience is not supporting understanding as effectively as it should.

This is where working with a specialist copywriting agency can help bring structure and consistency to the process.

FCA-compliant customer journeys - key principles

At Alex Genn Copywriting, we regularly work with firms that have strong individual content but weak overall journeys.

The issue is rarely a lack of effort. In fact, many organisations produce a high volume of content across multiple channels.

The problem is that this content has not been designed to work together.

Designing an effective journey doesn’t require starting from scratch. In most cases, it’s about organising and refining what already exists. A useful way to approach this is through four key principles.

Consistency

Consistency is about more than tone of voice. It ensures that key messages, particularly around risks and features, are aligned across all channels.

When customers encounter conflicting or inconsistent information, it creates confusion and undermines trust. The FCA expects you to manage this proactively rather than assuming it will not be an issue.

A consistent approach makes it easier for customers to build understanding over time.

Reinforcement

Important information shouldn’t be presented once and then left behind. The FCA highlights the value of “layering” information, where key messages are introduced early and then reinforced in different formats and at different stages of the journey.

This helps customers absorb complex information gradually, rather than being overwhelmed at a single point in time.

Reinforcement is particularly important for risk-related information, which should remain visible throughout the journey.

Progression

A well-designed journey has a clear sense of progression. Customers should move from general understanding to more detailed information in a logical sequence. Each step should prepare them for the next, rather than introducing entirely new concepts without context.

When progression is missing, customers are often forced to process too much information at once or fill in gaps themselves. This increases the likelihood of misunderstanding.

Accessibility

Finally, journeys must be accessible to a wide range of customers. This includes not only technical accessibility but also the ability to understand and engage with the content. The FCA expects you to consider different levels of financial knowledge and potential vulnerabilities.

Content that works for one audience may not work for another. A compliant journey takes this into account from the outset.

Why this matters under Consumer Duty

Recent guidance places a strong emphasis on supporting customers throughout their relationship with a business, not just at the point of sale.

This means that you need to consider how understanding develops over time and whether their communications continue to support good outcomes.

A fragmented or poorly structured journey can undermine this, even if individual pieces of content appear compliant.

On the other hand, a well-designed journey provides clear evidence that your business is actively supporting customer understanding.

FAQs on FCA compliance

What is an FCA-compliant customer journey?

An FCA-compliant customer journey is a sequence of communications that work together to help customers understand a financial product, its risks and its features over time. Rather than relying on a single piece of content, the journey should build understanding step by step and support informed decision-making at every stage.

Does the FCA assess individual content or the full journey?

The FCA assesses the overall customer experience, not just individual pieces of content.

This means firms must consider how communications interact across channels and whether the combined effect supports customer understanding and good outcomes.

Why is consistency across channels important for compliance?

Inconsistent messaging across channels can confuse customers and lead to misunderstandings.

The FCA expects firms to ensure that key information, particularly around risks and product features, is aligned across all touchpoints.

Consistency helps reinforce understanding and reduces regulatory risk.

How can marketing teams improve customer journeys?

Marketing teams can improve journeys by:

– Mapping the full customer experience

– Identifying gaps or inconsistencies in messaging

– Ensuring key information is introduced and reinforced clearly

– Structuring content to guide customers step by step

This often requires collaboration across teams rather than isolated content creation.

Do customer journeys need to account for vulnerable customers?

Yes. The FCA expects firms to consider a range of customer needs, including vulnerability. This includes ensuring that content is accessible, clearly structured and easy to understand for different levels of financial knowledge and capability.

What is meant by “layering” information?

Layering involves presenting key information upfront and then providing additional detail progressively, helping customers build understanding over time.

Does every touchpoint need to be compliant?

Yes. The FCA assesses the overall experience, not just individual communications.

No-one is an island. Isolation = risk

If your content is crafted in isolation, it may be creating unnecessary risk.

At Alex Genn Copywriting, we help financial services businesses design structured, FCA-compliant content journeys that improve clarity and consistency across every touchpoint.

Over the last 20 years, we’ve worked with some of the world’s largest brands, such as HSBC, Invesco, Santander, American Express, Rathbones, Tesco and The Virgin Group, as well as many SMEs and disruptive fintech startups.

Our 25 senior-level writers work in close collaboration with your team, sharing their financial expertise and creativity, to guarantee a successful outcome every time.

Get in touch to discuss how we can support your content strategy.

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Testing financial promotions: what the FCA expects and what most businesses miss

Alex Genn — Mon, 06 Apr 2026 09:12:11 +0000

What does the FCA say about testing?

In recent updates to their consumer duty guidelines, the FCA highlights testing as a key way to ensure consumer understanding.

This includes:

– User testing

– Behavioural insights

– Ongoing refinement

So, it’s no longer enough to make your best guess on what works, the FCA expects more.

Quick answer: why testing matters

Try not to think of it as another imposition or barrier to you getting your message over. Testing is incredibly useful to business.

It can help you identify misunderstandings. The process can give you a laser focus on clarity, and certainty of approach.

And beyond that it can support you with evidence compliance.

The dangerous gap for most businesses

Over the last 20 years, working with financial services businesses, we’ve seen many businesses that rely solely on internal review processes.

The truth is, while that’s a useful process, what it doesn’t give you is real customer understanding.

It’s only by undertaking specific audience research, that you can be sure you’re not only really connecting with your audience, but that you’re avoiding the pitfalls which will mean you fall foul of the FCA.

In short, if you’re only testing internally, you’re creating dangerous blind spots.

The right experience counts

The fact is, FCA compliance is a tricky beast. One of the easiest ways to avoid falling foul of the rules is to make sure your team has the right experience, as well as the ability to stay aware of the latest updates. For many financial services businesses, outsourcing to experts can bring peace of mind.

At Alex Genn Copywriting, our 25 senior-level copywriters have an abundance of experience in financial services. They make it their business to stay up to date on the regulations, complement their creativity, sharp interviews, quality research and authoritative writing.

Evidence and testing - a practical approach check

Do you have evidence that your audience understands your content?

If not, you may be opening yourself up to a potential compliance risk. We’ve been through the most recent updates to the regulations and put together a simple approach to help you get it right…

A practical approach to testing

Define key messages: What is it that’s most important for users understand?

Test with real users: Gather feedback on comprehension from actual people

Refine content: Iterate and improve based on insights, and make sure you keep a record

Repeat: Make testing part of your process, every time

If you follow these fairly straightforward steps, you’ll be more likely to stay on the right side of the FCA.

FAQs about FCA compliance an testing

Is testing mandatory?

Not always, but increasingly expected.

What should be tested?

Any content that influences financial decisions.

Does this apply to all content?

Yes. The principles apply across all financial promotions and business writing.

What is FCA-compliant content?

Content that is clear, fair and not misleading, and enables informed decision-making.

Put us to the test

Testing is not just a compliance exercise. It’s a genuinely valuable way to improve the performance of your marketing communications.

At Alex Genn Copywriting, our client experience includes: Invesco, Rathbones, Santander, HSBC, CMC Markets, Atradius Credit Insurance, Moody’s Analytics, Close Brothers, St James’s Place, The Trident Trust, The Virgin Group and many others.

We support a wide range of financial services brands from global giants and SMEs to disruptive fintech startups, to create powerful content that’s as compliant as it is effective.

Get in touch to discuss your next project.

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How to create FCA-compliant content that is clear, fair and not misleading

Alex Genn — Fri, 27 Mar 2026 11:53:21 +0000

What does “clear, fair and not misleading” actually mean?

“Clear, fair and not misleading” is one of the most widely quoted FCA requirements.

But in practice, many marketing teams still treat it as a wording exercise.

The FCA’s Consumer Duty guidance makes it clear that this is not enough. Communications must actively support customer understanding and enable informed decisions, not simply avoid being incorrect.

Quick answer: how to create FCA-compliant content

There’s no two ways about it, to meet FCA expectations, there are clear non-negotiables. Your content must:

– Be easy to understand for the target audience

– Present risks and benefits in a balanced way

– Avoid ambiguity or exaggeration

– Be designed with structure and clarity in mind

This requires more than editing. It requires a different approach to writing.

Why businesses still get this wrong

Most financial promotions are created under commercial pressure. Marketing teams are thinking about getting their message across. As they should be. But with that single focus, there is a natural tendency to lead with benefits, simplify messaging for impact and/or add disclaimers later

The FCA has identified this as a key issue, particularly where risks are de-emphasised or difficult to find.

Over time, this creates a disconnect between what businesses intend to communicate and what customers actually understand. And that’s bad news for everyone.

Authority insight: where risk really comes from

At Alex Genn Copywriting, we’ve been working with financial services businesses (such has Invesco, HSBC, Rathbones and Moody’s) for over 20 years. We often review content that has already passed compliance checks.

On the surface, it appears compliant. But when you look closer, the risks become clear:

– Key information isn’t prominent

– Language assumes prior knowledge

– Structure makes comparison difficult

This is where many businesses unintentionally fall short of FCA expectations. These are issues that all of our 25 senior-level writers are naturally aware of, so these are pitfalls we help our clients avoid.

Would your content stand up alone?

A useful test is to isolate a single piece of content. Remove brand context. Remove supporting materials. Then ask yourself, would a customer still understand the following:

– The product

– The risks

– The limitations

…If not, the content may not be meeting FCA expectations.

This is where working with a specialist financial services copywriter becomes valuable, not just for writing but for structuring information correctly.

A useable framework for clear, fair and not misleading content

Balance

Content should present risks and benefits with equal clarity. The FCA has highlighted that overemphasis on benefits is a recurring issue, particularly in financial promotions. This doesn’t mean reducing impact. It means ensuring that customers can make informed decisions based on a complete picture.

Precision

Ambiguous language creates risk. Phrases like “potential returns” or “competitive rates” may be technically accurate but lack clarity without context. The FCA expects you to consider how customers interpret information, not just how it is written.

Transparency

Important limitations should not be hidden. The FCA has emphasised that key information should be presented upfront, not buried in supporting text or disclaimers. Transparency builds trust and reduces regulatory risk.

Readability

Structure is not just a design choice. It is a compliance issue. Give careful consideration to how your work actually comes across.

The FCA highlights the importance of:

– Clear hierarchy

– Logical flow

– Accessible formatting

These elements directly affect understanding, so don’t underestimate their importance. Think of it this way: the easier you make it for readers to engage with and understand your content, the better.

Why this is important under Consumer Duty

As with all guidance, you need to dig into it. And when you do, you can gain a really clear understanding of what you’re expected to do:

– Act in good faith

– Avoid causing foreseeable harm

– Support customers in achieving their financial objectives

Poorly structured or unclear content can undermine all three of these. The message is clear: communication is now central to compliance, no longer just supporting it.

FAQs

What makes content misleading?

Content can be misleading if it omits key information, presents it unclearly, or creates an unbalanced impression.

Are disclaimers enough?

No. The FCA expects clarity throughout the content, not just in disclaimers.

Does this apply to all content?

Yes. The principles apply across all financial promotions and business writing.

What is FCA-compliant content?

Content that is clear, fair and not misleading, and enables informed decision-making.

Do businesses need to work with an external financial services writer?

An external writer will have up-to-date knowledge of FCS regulations as well as broad financial content experience.

Ready to go beyond wording?

Creating FCA-compliant content requires more than careful wording and remembering your disclaimers. It requires a structured, informed approach to communication.

At Alex Genn Copywriting, we support financial services businesses with professional writing that meets FCA expectations while remaining clear and engaging. Whether you’re a global business, SME or a disruptive start-up, we can help.

We give you a senior-level writer who will work as an extension of your team. Beyond their financial expertise, our writers are also easy to work with, prioritising collaboration and feedback, not their ego.

Talk to us today to discuss how we can make sure your content is as engaging and effective as it is compliant.

The post How to create FCA-compliant content that is clear, fair and not misleading appeared first on Alex Genn Copywriting.

What the FCA really means by consumer understanding (and why most financial promotions fall short)

Alex Genn — Thu, 26 Mar 2026 14:25:13 +0000

How do you create FCA-compliant content that improves consumer understanding and reduces regulatory risk for financial promotions? Good question. We’ve looked at the latest FCA guidance…

What is consumer understanding according to the FCA?

Consumer understanding means ensuring that customers can:

– Understand product features, risks and costs

– Make informed financial decisions

– Compare products effectively

This goes beyond accuracy. The FCA expects firms to demonstrate that their communications actually work for real customers.

Quick answer: what makes content FCA-compliant?

FCA-compliant content must be:

– Clear, fair and not misleading

– Easy to understand for the intended audience

– Structured to highlight key information

– Designed to support informed decision-making

What do you notice about all these? Together they end one very strong messgae: accuracy alone is not enough.

The problem: compliant wording doesn’t guarantee understanding

If your financial promotions are technically correct, is that enough?

The FCA says no.

Many firms still rely on compliance sign-off as proof that content works. In reality, the FCA highlights that firms often overestimate how well customers understand what they are being told.

Why this matters for marketing teams

At Alex Genn Copywriting, we have over 20 years of experience producing financial services content for firms including Lloyds Banking Group, HSBC, Santander and Invesco Perpetual.

A consistent issue we see is content that passes compliance review but fails to support genuine understanding.

This is exactly the gap the FCA is now focused on closing.

Where financial promotions fall short

Key information is buried

Important details are often difficult to find or overshadowed by promotional messaging.

Language is technically correct but unclear

Terms like “capital at risk” may be accurate but not always meaningful without context.

Structure works against comprehension

Poor hierarchy and layout make it harder for users to engage with content.

Is your content reducing risk?

If you tested your content with real users, would they understand it?

Many businesses lack the internal capability to answer that confidently. Working with a specialist copywriter for FCA compliance can help ensure content is built with both clarity and regulation in mind.

A practical framework for FCA-compliant content

Before you get started, make a note of this framework. In fact, put it on a post-it, stick it to your desk, and refer to it regularly. You won’t regret it.

Clarity

Use plain English and remove unnecessary jargon

Structure

Make key information easy to find

Context

Explain risks in relatable terms

Continuity

Ensure content works across the full journey

Why this matters now

The FCA’s focus aligns with Consumer Duty expectations around good customer outcomes. Content is no longer just marketing. It’s part of compliance.

FAQs: FCA-compliant content

What is FCA-compliant content?

Content that is clear, fair and not misleading, and enables informed decision-making.

Who is responsible for compliance?

Both marketing and compliance teams share responsibility.

Does content need to be tested?

The FCA increasingly expects firms to test communications where appropriate.

Do businesses need to hire a specialist in financial services writing?

An external agency can guarantee an up-to-date understanding of regulations, wide financial services experience and the creativity to bring it all together.

Staying compliant shouldn't be arduous

Creating FCA-compliant content requires more than technical accuracy. It requires a blend of expereice and creativity that can be hard to find.

At Alex Genn Copywriting, we’ve been makign it easy for financial services firms to publish complaint marketign for over 20 years. From articles and whitepapers to annual reports and site content, we make sure you meet regulatory expectations.

Get in touch to discuss how we can support your next project.

The post What the FCA really means by consumer understanding (and why most financial promotions fall short) appeared first on Alex Genn Copywriting.