Self-approving your financial promotions as a DA mortgage firm: what the FCA actually requires
A directly authorised firm needs no external approval to publish its own marketing — the 2024 "approval gateway" does not apply to your own posts. What the FCA does require: internal sign-off by a named, competent person in your firm, promotions that are compliant standing alone, and records kept off-platform for at least 12 months after a promotion last ran. You are the approver. The job is doing it properly — and being able to prove you did.
Do I need anyone's approval to post? No — you're already it.
Under section 21 of FSMA, a financial promotion is lawful when it's communicated by an authorised person. A directly authorised firm is an authorised person — so your own promotions, in your own name, need no external approver. There is no queue, no network portal, nobody to wait on.
That's the freedom. The catch is that the responsibilities a network compliance department would carry sit with you instead — and the FCA has been explicit that it's watching this space (more below).
"But what about the 2024 approval gateway?" — it's not about you.
This one confuses a lot of DA principals. Since 7 February 2024, an authorised firm needs special FCA permission to approve financial promotions for unauthorised persons (FSMA s55NA, introduced by PS23/13). The key words are for unauthorised persons — think of a firm approving an unregulated introducer's advert.
A firm communicating its own promotion in its own name is unaffected. You do not need gateway permission to sign off your own marketing. If you've been holding back posts because of the gateway, you've been solving a problem you don't have.
What the FCA does require: named internal sign-off
The FCA's social media guidance, FG24/1 (March 2024), sets the expectation plainly:
"an adequate system in place to sign off digital media communications… This sign-off should be by a person of appropriate competence and seniority within the organisation."FG24/1, para 3.15
In a small DA firm, that person is usually the principal — you. The point isn't ceremony; it's that someone competent looks at each promotion before it goes out, and the firm can show who and when. MCOB 3A.9.1R frames the same step as the firm "confirming" each promotion complies before recording it.
Remember the baseline every promotion is being confirmed against: fair, clear and not misleading; balanced (benefits don't outshine risks); the standard warnings where required — on mortgage promotions, "Your home may be repossessed if you do not keep up repayments on your mortgage" — plus your status disclosure, and each post compliant standing alone, without relying on a linked page or a "see more" click.
The records: your evidence is your protection
MCOB 3A.9.1R requires an adequate record of each non-real-time financial promotion you've confirmed as compliant, kept for at least a year from when it was last communicated — note that an evergreen post keeps that clock running. And FG24/1 adds a detail many firms miss:
"Firms should not rely on digital media channels to maintain records… Social media platforms may refresh content from time to time, deleting older material."FG24/1, para 3.16
A sensible record for each promotion looks like this:
| Keep | Why |
|---|---|
| Final content as published | Exactly what the public saw — image, caption and all, per channel |
| Who confirmed it, and when | The named sign-off FG24/1 expects; your proof it happened |
| Versions and amendments | Shows the checking actually changed things — evidence of a working system |
| Where and when it ran | Start/end dates drive the retention clock |
| Withdrawal log | If you pulled or fixed something, the record shows you acted |
Twelve months is the MCOB minimum — many firms sensibly keep promotion records for six years, in line with complaint timeframes. Stored off the platforms, exportable if the FCA ever asks.
Why this matters more now than in 2021
The FCA's January 2025 letter to mortgage intermediaries names social media promotions as a continuing supervisory priority: "Social media is a widely used marketing channel for mortgage intermediaries… We will continue to closely monitor firms' compliance with our financial promotion rules." The direction of travel is one way. For a DA firm the practical response isn't to go quiet — it's to have a system: check before posting, sign off by name, keep the evidence.
A workflow a small firm can actually run
- Sort every post before writing: lifestyle (no financial content — normally not a promotion at all), education (needs warnings, disclosure, no call to action... and a judgement call), or promotion (full checks, full record).
- Check against a fixed list: warnings present and prominent, status disclosure, balanced, no banned hype, no invented figures, standalone-compliant.
- Sign off by name: the confirming person and date, every time — even when it's the same person writing and confirming.
- Record off-platform: final content, versions, dates, sign-off — filed where a platform can't delete it.
This is exactly what Made for Brokers does all day.
Drafts your content in your brand and voice, checks it against a checklist built on MCOB 3A and FG24/1, routes it to your named sign-off person — you stay the approver — and keeps the exportable audit trail, beyond the FCA's 12-month minimum. Made by a practising UK adviser. Founding 15 opens autumn 2026.
Join the waitlistSources
- FCA, FG24/1 — Finalised guidance on financial promotions on social media (March 2024): fca.org.uk/publication/finalised-guidance/fg24-1.pdf
- FCA Handbook, MCOB 3A (financial promotions of qualifying credit) incl. MCOB 3A.9.1R record-keeping: handbook.fca.org.uk/handbook/MCOB/3A/
- FCA Handbook, SYSC 9.1 (general record-keeping): handbook.fca.org.uk/handbook/SYSC/9/1.html
- FCA, Applying to approve financial promotions for unauthorised persons (the s55NA gateway): fca.org.uk/firms/financial-promotions-adverts/applying-approve-unauthorised-persons
- FCA, Financial promotions data 2024: fca.org.uk/data/financial-promotions-data-2024
- FCA, portfolio letter to mortgage intermediaries (30 January 2025): fca.org.uk/publication/correspondence/fca-strategy-mortgage-intermediaries.pdf
The small print: this guide is general information for UK mortgage & protection professionals, written by a practising adviser — it is not legal, regulatory or compliance advice, and rules change: always check the source documents linked above. Responsibility for your firm's financial promotions remains with your firm. Made for Brokers is not a law firm or compliance consultancy.