Rule coverage
Every rule, and exactly how a finding is grounded.
This is the domain IP: a maintained, versioned set of FCA financial-promotion rules. For each one, here’s the Handbook reference, what a compliant promotion must satisfy, and a worked example of the verbatim text a finding would quote. Open any rule to see how the grounding works.
Rule set fca-cobs4-v1-2026-07 · 10 rules
[FCNM]Fair, clear and not misleading+
COBS 4.2.1R
The promotion must be fair, clear and not misleading. Flag exaggerated claims, cherry-picked figures, ambiguous wording, or anything a retail reader could reasonably misunderstand.
Illustrative example (synthetic)
“The best, safest, most rewarding investment you'll ever make.”
“The best, safest, most rewarding investment you'll ever make”
Fix: Remove unsubstantiated superlatives; make claims specific, balanced and evidenced.
[BAL]Balanced presentation of benefits and risks+
COBS 4.5.2R
Benefits and risks must be given equal prominence. Flag promotions that lead with returns/upside while burying, minimising, or omitting the corresponding risks.
Illustrative example (synthetic)
“Earn a fantastic 15% a year with our property bond! (Capital at risk.)”
“Earn a fantastic 15% a year with our property bond!”
Fix: Give the risks equal prominence to the returns, not a bracketed afterthought.
[RISKWARN]Capital-at-risk / prescribed risk warning+
COBS 4.2 / COBS 4.12A
INVESTMENT promotions must carry a clear, prominent capital-at-risk warning (e.g. 'your capital is at risk' / 'you may get back less than you invest'). High-risk investments require the specific prescribed risk warning. Flag if missing or not prominent. This rule does NOT apply to cash deposits or FSCS-protected savings accounts, never flag those for a missing capital-at-risk warning.
Illustrative example (synthetic)
“Invest in our global fund from just £25 a month. Open an account in minutes.”
Omissiona required element is missing, nothing to quote
Fix: Add a clear, prominent capital-at-risk warning, e.g. 'Your capital is at risk. You may get back less than you invest.'
[GUARANTEE]No misleading guarantees of return+
COBS 4.2.1R
Flag any guarantee or strong implication of a specific INVESTMENT return, 'risk-free', 'guaranteed profit', or 'can't lose' language unless it is genuinely and verifiably guaranteed and the guarantor is named. An advertised interest rate or AER on a deposit/savings account is NOT a prohibited guarantee of return, never flag it.
Illustrative example (synthetic)
“Guaranteed 12% annual returns, completely risk-free. Get started today.”
“Guaranteed 12% annual returns, completely risk-free”
Fix: Remove 'guaranteed' and 'risk-free' unless genuinely guaranteed by a named guarantor.
[PASTPERF]Past performance not presented as a guide to the future+
COBS 4.6.2R
Where past performance is shown, it must state that past performance is not a reliable indicator of future results, cover an adequate period, and not be the most prominent feature. Flag misuse.
Illustrative example (synthetic)
“We've beaten the market every year since 2015, returns like these speak for themselves.”
“We've beaten the market every year since 2015”
Fix: State that past performance is not a reliable indicator of future results; cover an adequate period.
[COSTS]Costs, charges and material terms disclosed+
COBS 4.2 / PRIN
Material costs, charges, fees, lock-ins, or conditions that affect the customer must not be hidden or omitted where their absence would mislead. Flag missing or obscured material terms.
Illustrative example (synthetic)
“Zero-commission investing! Keep more of your returns.”
“Zero-commission investing!”
Fix: Disclose material costs, the annual management fee, any exit charge or subscription, where their absence would mislead.
[IDENT]Clear identification as a financial promotion+
COBS 4.3 / PERG
It must be clear the communication is a financial promotion and who is communicating/approving it. Flag promotions that disguise themselves as neutral news, editorial, or personal opinion.
Illustrative example (synthetic)
“OPINION: why smart savers are quietly moving their pensions into this one fund.”
“OPINION: why smart savers are quietly moving their pensions into this one fund”
Fix: Make clear the communication is a financial promotion and who is communicating or approving it.
[TARGET]Appropriate for the target audience+
COBS 4.2 / COBS 4.12A
The promotion must be appropriate for the audience it will reach. Flag complex/high-risk products promoted to a general retail audience without appropriate categorisation or restrictions.
Illustrative example (synthetic)
“New to investing? Jump straight into our leveraged crypto CFDs, anyone can start with £50.”
“New to investing? Jump straight into our leveraged crypto CFDs”
Fix: Restrict high-risk products to appropriately categorised audiences; add the required warnings and appropriateness step.
[S21]Section 21 approval / authorised communicator+
FSMA 2000 s21
A financial promotion must be made or approved by an FCA-authorised person unless an exemption applies. Flag if the content implies an unauthorised firm is communicating without approval or a stated exemption.
Illustrative example (synthetic)
“Fund our mini-bond and earn 8% fixed. This promotion is not approved by an authorised person.”
“This promotion is not approved by an authorised person”
Fix: Have the promotion made or approved by an FCA-authorised person, or rely on a stated exemption.
[SOCIAL]Standalone compliance (social/short-form)+
FCA FG24/1
Each promotion must be compliant and balanced on its own, risk warnings cannot be relegated to a linked page, thread reply, or 'see bio'. Flag short-form/social promotions that omit required warnings from the standalone piece.
Illustrative example (synthetic)
“Big returns with our new fund! Full risk warnings in our bio. #investing”
“Full risk warnings in our bio”
Fix: Include the required risk warning in the standalone post, it cannot be relegated to a linked page or 'see bio'.
Examples are synthetic and illustrative, they show how grounding works, not real client promotions. In the product, every finding quotes verbatim text from your own promotion, and anything it cannot ground is dropped.
Run your own promotion against these rules.
Every finding you get is pinned to one of the rules above, with the exact text quoted and a defensible, exportable record.
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