The playbook
How to run a financial-promotion review you can defend.
Since the s21 financial-promotion approver gateway went live in February 2024, the bar is not just “is this promotion compliant?” but “can I evidence that my review was competent and my controls worked?” The FCA’s 2026 review of approvers found several firms needed to raise standards. Here is a practical, seven-step checklist, useful whatever tool you use.
Identify the product type first
A cash deposit, an investment, consumer credit, a pension and a cryptoasset are governed by different rules. Applying investment risk-warning rules to an FSCS savings ad is a false positive; missing them on a high-risk investment is a real breach. Pin the product type before anything else.
With PromoCheck: PromoCheck classifies the product type and applies only the rules that apply, so a compliant deposit passes cleanly.
Map each claim to a specific rule
For every claim in the promotion, ask which Handbook provision it engages: COBS 4.2.1R (fair, clear, not misleading), 4.5.2R (balance), 4.6.2R (past performance), 4.12A (high-risk), FSMA s21 (approval), FG24/1 (social/standalone). A finding without a rule behind it is an opinion, not a review.
With PromoCheck: Every PromoCheck finding names a specific rule and its Handbook reference, nothing is raised without one.
Quote the exact triggering text
Record the verbatim words that create the issue, not a paraphrase. When the FCA, your board, or your PI insurer asks 'why did you flag/allow this?', the defensible answer is the exact phrase and the exact rule, not a summary.
With PromoCheck: Findings quote verbatim text from the promotion; anything that can't be quoted is dropped in code.
Say when you can't tell
If a piece is too thin or ambiguous to assess, record that, and what you'd need to assess it, rather than forcing a judgement. A confident wrong answer is worse than an honest 'insufficient information'.
With PromoCheck: PromoCheck returns INSUFFICIENT_GROUNDING and lists what it would need, instead of guessing.
Record the rationale and the rule-set version
COBS 4.11 expects an adequate record of each promotion and the basis for the decision. Capture which rules were applied, the outcome, and the version of your rulebook at the time, rules change, and you must be able to show what applied when.
With PromoCheck: Every review is recorded with the versioned rule set applied, timestamped, in an exportable evidence pack.
Escalate disagreement to a human
Where a judgement is genuinely borderline, it should be escalated and decided by a named, competent person, not auto-cleared. Document who decided and why.
With PromoCheck: High-assurance mode runs two independent models; any disagreement is escalated for human review, never auto-cleared.
Keep a tamper-evident trail and name the approver
Under SM&CR a named senior person is accountable, and you must be able to evidence that your controls operated effectively. That means a durable, verifiable record, one that can be shown to be unaltered, not a spreadsheet anyone can edit after the fact.
With PromoCheck: The audit trail is hash-chained and signed; any later change fails verification, and the whole trail exports for a regulator request.
This is general guidance on running a defensible process, not legal or regulatory advice. Responsibility for a financial promotion rests with the regulated firm, and a suitably qualified person must make the final decision.
Automate the checklist.
PromoCheck runs steps 1-7 in one pass and hands you the defensible record, you stay the approver.