Working With Finfluencers: What IFAs Actually Need to Know About Compliance

The idea of partnering with a financial influencer probably sounds appealing. Someone with 50,000 engaged followers talking about your services could bring in more leads than six months of networking events. But before you slide into anyone's DMs with a collaboration proposal, you need to understand exactly what the FCA expects—because the consequences of getting this wrong are severe.

A new guide from Global Relay has brought together the key compliance requirements for financial services firms working with finfluencers. Let's break down what this means for your practice.

Section 21 FSMA: The Rule That Changes Everything

Here's the bit that catches people out: under Section 21 of the Financial Services and Markets Act, communicating a financial promotion when you're not authorised (or your content hasn't been approved by an authorised firm) is a criminal offence. Not a regulatory breach. Not a fine. A criminal offence carrying up to two years in prison.

This applies to the influencer, not just to you. But here's where it gets complicated for IFAs: if you're the authorised firm approving a finfluencer's content, you're taking on responsibility for everything they say.

Every Instagram story. Every TikTok video. Every reply in the comments.

What FG24/1 Actually Says About Social Media

The FCA's guidance note FG24/1 specifically addresses social media content, and it's broader than most people realise. It covers:

• Memes and informal content: That jokey graphic about pension contributions? Still a financial promotion if it's encouraging people to use your services.
• Private Discord channels and WhatsApp groups: The FCA explicitly states that "private" doesn't mean unregulated. If an influencer is promoting financial products in a closed group, the same rules apply.
• Ephemeral content: Stories that disappear after 24 hours are still financial promotions while they're live.

The guidance makes clear that the format doesn't matter. A 15-second TikTok needs to meet the same standards as a 20-page brochure.

The Consumer Duty Angle

Consumer Duty adds another layer. Any communication with retail customers needs to support good outcomes. For finfluencer content, this means:

1. The audience must be able to understand the content: If an influencer's followers are predominantly 18-24 year olds with limited investment experience, the content needs to reflect that.

2. Risk warnings can't be buried: That tiny disclaimer in the caption that nobody reads? Not good enough. The FCA wants risk information to be as prominent as the benefits.

3. The overall impression matters: You can't have an influencer gushing about returns for 58 seconds and then mumble "capital at risk" in the final two seconds.

Practical Steps If You're Considering Finfluencer Marketing

1. Pre-approve everything

Not just the script—the actual content. Video, graphics, caption, hashtags. All of it. Before it goes live.

2. Document your approval process

You need to show the FCA that you had a robust process. This means keeping records of:

• The original content submitted
• Your review and any amendments requested
• The final approved version
• Evidence that what went live matched what you approved

3. Monitor ongoing content

Influencers respond to comments. They go live. They post stories. If they're promoting your services, you need a way to monitor what they're saying in real-time. This is operationally difficult, which is why many firms decide finfluencer marketing isn't worth the risk.

4. Have a clear contract

Your agreement should specify:

• Exactly what content is approved
• That no variations are permitted without written approval
• Your right to require immediate takedown
• Indemnities for regulatory breaches

5. Check their other content

If an influencer is also promoting crypto schemes, get-rich-quick courses, or other high-risk products, associating your brand with them creates reputational and regulatory risk—even if your specific content is compliant.

The Numbers That Should Make You Pause

Last year, the FCA issued over 2,000 warnings about potential scam firms operating online. They're actively monitoring social media and have dedicated resources to identifying non-compliant promotions.

The regulator has also been clear that it views firms approving influencer content as taking on full responsibility. If an influencer goes off-script, the FCA won't accept "but that's not what we approved" as a defence if your monitoring was inadequate.

Is It Worth It?

For some IFAs, a carefully managed finfluencer relationship can work. But it requires significant compliance infrastructure: pre-approval workflows, real-time monitoring, documented processes, and legal agreements.

For most independent practices, the operational burden outweighs the benefits. You might be better served by building your own compliant social media presence—content you control, on platforms you monitor, with messaging you've verified.

Whatever route you choose, the rules are clear: every piece of content that could encourage someone to use your financial services needs to be compliant before it goes live.

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