The UK financial promotion regime is going through a series of complex and interconnected changes that are being legislated for and implemented in a somewhat piecemeal manner, meaning that it is not straightforward for firms to keep abreast of all the changes or to see the bigger picture.

This is acutely illustrated by the FCA consulting in December on final guidance it published in August but which went out of date before coming into force (due in February)! The impact of the changes will vary depending on the sectors in which firms operate and the products they offer.

The changes will impact unauthorised firms publishing financial promotions, and FCA authorised firms publishing and approving financial promotions.  The changes vary across product and investment types, and some exemptions may be made narrower and harder to rely on.

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