It’s easier to produce marketing content in a regulated firm when you change the workflow to build in compliance concerns much earlier. Content can become delayed in review when written before key claims and compliance requirements have been considered. Agreeing key claims before drafting, maintaining a library of approved language and involving compliance in the brief can all help make the review process more efficient.
Why does some financial services content die in review?
One common challenge is timing. The copy gets written for readability, then it goes to compliance for accuracy, with these two roles meeting at the latest possible moment. By then the writer is attached to the structure, the deadline is close, and every edit feels like a loss. And when compliance first sees a finished draft, it may identify issues with the underlying claims or audience that require substantial changes.
The result is a draft that dies by a thousand comments. You rewrite, resubmit, and potentially lose a week. For wealth and asset management teams, repeated rounds of review can make it harder to deliver content consistently. The problem is structural, and structure is something you can change.
Is this a financial promotion, and why does that distinction decide everything?
Under the UK financial promotion regime, a financial promotion is broadly defined as an invitation or inducement, communicated in the course of business, to engage in investment activity. FCA rules, including COBS 4 where applicable, set out requirements for relevant communications and promotions. If a piece of content nudges someone towards a product, a fund or a service, treat it as a promotion until compliance tells you otherwise.
The line matters because it decides which rules apply. Relevant promotions must be fair, clear and not misleading. They should present benefits and risks in a balanced way and be designed with their intended audience in mind. A genuinely educational article with no inducement sits somewhere else. The distinction is not always obvious to a writer, so it is worth checking early in the process. Thought leadership that mentions your own fund may raise questions about whether the piece is promotional, so involve compliance in that assessment.
Why should you agree the claim before writing the copy?
Agree the claim first, then write to it. The claim is the single assertion the content exists to make: this fund did this, this service does that, this is who it suits. If compliance can review the core claim before drafting begins, the writer has a clearer starting point and can avoid substantial changes later.
This works because most compliance objections are substantive rather than about wording. When you settle the core assertion up front, you find the hard problems in a meeting instead of in a marked-up document. You might learn that a performance figure needs a time period, that a claim using the word “guarantee” needs closer scrutiny, or that a comparison needs a like-for-like basis. Decide on these so that the writer can then build the piece around a claim that has already had initial compliance input. This order of operations is the key to efficient content production.
How do you build a pre-approved language library?
A pre-approved language library is a catalogue of words and phrases compliance has already cleared. Each entry should record what the wording was approved for, including the relevant product, audience and context. You build it by collecting the sentences that survived past reviews and recording the exact phrasing that passed. Over time, you develop a bank of risk warnings, product descriptions and benefit statements that can provide a useful starting point for future content.
Keep it specific. Record approved descriptions of stocks and shares ISA, the sanctioned wording for past performance, and the agreed phrasing for tax treatment. Note what is banned and why. Date each entry. Approved wording may need to be reviewed when rules, products or circumstances change.
A well-maintained library can reduce repeated drafting and give reviewers a consistent starting point. Of course, the finished communication still needs to be checked in its intended context.
How do you bring compliance into the brief?
You invite compliance to the kickoff rather than the final draft. Give the reviewer the idea, the audience, and the core claim while the piece is still cheap to change. A conversation at the brief stage can identify objections while the idea is still easier to change.
Treat compliance as a design input. Ask the reviewer what would make this piece easy to approve and what would make it impossible. Most reviewers will tell you plainly. Early input gives both teams an opportunity to resolve substantive questions before time is spent developing a full draft. In our financial services work, we use this method to involve compliance early, reducing the amount of time spent on later reworkings.
What did Consumer Duty change about tone as well as substance?
The FCA’s Consumer Duty is a set of rules designed to ensure financial services firms deliver good outcomes for retail customers. One part of the Duty focuses on consumer understanding: firms need to consider whether their communications give customers the information they need in a way they can understand.
For content teams, that means accuracy is essential, but so is clarity. A technically correct sentence may still be difficult for its intended audience to understand.
Firms now need to consider whether their communications support the intended audience’s understanding and help customers make informed decisions.
That makes tone a compliance matter, because a technically correct sentence that confuses the reader can fail the standard.
The FCA has been explicit about what it expects. In ‘Consumer Duty outcomes monitoring: good practice and areas for improvement’, published on 27 July 2026, the regulator set out where firms were meeting the consumer understanding outcome and where they were falling short. In ‘Products and services: good practice and areas for improvement’, published on 10 July 2026, it did the same for product governance. And in the FCA multi-firm review of Consumer Duty price and value practices in unit-linked pensions and savings, published on 2 July 2026, it showed how far the value question now reaches into everyday product communications.
The practical shift is that plain language is now the safe choice for communication with customers, not jargon. Some firms responded by rewriting their disclaimers. But understanding depends on the whole communication, so firms should consider the clarity of the body copy as well. If the main copy relies on language the intended audience may not understand, clearer disclaimers alone are unlikely to solve the problem.
Can you use AI for drafting without creating a sign-off problem?
Yes, AI can be of assistance for drafting, but there needs to be a hard rule when it comes to sign-off. AI can produce a first draft, summarise a factsheet or generate variations on approved copy at speed. It cannot approve anything, and it cannot be the reason a claim exists.
The sign-off problem is accountability. Firms remain responsible for the communications they publish, including content drafted with AI. Their internal process should make clear who reviews and approves the finished piece.
Keep AI inside the library rather than outside it. Approved language can give an AI tool a useful starting point, but the output still needs to be checked for accuracy, context and appropriate use of risk information. Ideally, keep a record of what the model drafted and what a human employee changed, because a reviewer could want to see where human judgement was involved in the process. We all want to move fast, but speed shouldn’t entail extra risk.
What does one idea look like taken through the whole process?
Take an ISA campaign idea and run it end to end. Say you want to encourage people to use their stocks and shares ISA allowance before the 5 April tax year end. That is an inducement to engage in investment activity, so it is technically a financial promotion under COBS 4.
At the brief stage, the team discusses the proposed claim with compliance: that a stocks and shares ISA can shelter investment growth from certain taxes. The discussion also identifies information the campaign may need to include, such as the fact that tax treatment depends on individual circumstances and can change, and that investments can fall in value.
You pull the risk warning and the tax wording from the pre-approved language library, both of which have already been cleared. The writer drafts around a claim that has had initial compliance input. The full draft then goes back to compliance, with the main claim and supporting wording already discussed. This should help the piece ship before the deadline, which for ISA season is a vital metric. Compare that with the usual route, where the same idea reaches compliance on 1 April with a headline nobody is sure is defensible.
What belongs on the approval checklist?
Before anything goes to compliance, we suggest a 9-step checklist run in this order. The following questions can help a team prepare content for compliance review.
- Has compliance assessed whether the content is a financial promotion, and which requirements apply?
- Have the key claims been discussed with compliance before drafting? Ideally, this should be condensed to a single defensible sentence.
- Is every factual assertion sourced, dated and current?
- Are benefits and relevant risks presented clearly and in a balanced way?
- Is the language drawn from the pre-approved library where possible?
- Has the team considered whether the intended audience will understand the key information, and whether testing is appropriate?
- Are performance and tax claims accurate, appropriately qualified and supported by the relevant source, dates and context?
- Is there a named human accountable for sign-off?
- If AI was used, has its output been reviewed in line with the firm’s policies?
We work with clients whose content needs to pass through regulated approval processes. Every single person in our team undergoes intensive financial promotions training. If you need support producing content within a regulated approval process, talk to us.
Importantly, Rostrum is not a compliance adviser. This is how communications teams work best with compliance. It is not legal or regulatory advice, and you should have your own compliance function or an external consultant review anything before it goes out.
Frequently asked questions
What counts as a financial promotion?
A financial promotion is broadly an invitation or inducement, communicated in the course of business, to engage in investment activity. Whether a particular piece of content falls within the regime depends on its content and context, so ask compliance to assess it. A compliance function should check any content or campaign against FCA guidelines.
How do you get marketing content approved by compliance faster?
Change the order of operations. Agree the core claim before you write, build a library of pre-approved language, and bring compliance into the brief instead of the final draft. The arguments then happen once, at the cheapest moment to resolve them.
What did new Consumer Duty guidelines change for marketing?
It moved the test from an issue of accuracy to understanding, which makes tone a compliance matter. Consumer Duty places greater emphasis on whether communications support retail customers’ understanding and help them make informed decisions.
Can you use AI to write financial services marketing content?
Yes, for drafting, so long as a human is accountable for sign-off. Follow your firm’s policies on recording AI use, and make sure the finished content goes through the appropriate review.
