How can you advertise on Google and Meta without an FCA number?

What does Google ask for?

Google requires advertisers who promote financial services to users in the UK to complete its financial services verification. Its UK help page sets out four categories.

• FCA-authorised advertisers. Firms authorised by the FCA, or listed on the register as an exempt professional firm or a recognised investment exchange, verify with their firm reference number. The business details given have to match the register.
• Approved third parties. Businesses whose adverts are approved by an FCA-authorised firm, such as resellers, affiliates and lead generation agencies. The authorised firm starts the verification by listing your websites, it can only vouch for businesses whose promotions it approves, and you have to tell Google straight away if the approval ends.
• Exempt non-financial services advertisers. Businesses that do not promote financial services but have a good reason to reach people looking for them, such as search engines and online marketplaces. They have to confirm that they will not use the exemption to run financial services adverts.
• Exempt government entities, such as UK government bodies and regulators.

Google may also ask you to complete its general advertiser verification.

What does Meta ask for?

Meta requires verification for adverts that promote financial products and services to people in the UK, such as insurance, mortgages, loans, investments and credit cards. In the UK the process centres on the FCA register: you give a firm reference number and confirm it through contact details that match the register entry.

Meta says some adverts can generally run without verification as long as they do not focus on a particular financial product or service. These include brand adverts for banks and insurers, news about financial products, financial education and educational adverts that do not let people obtain or connect with a product. Meta does not describe an equivalent of Google’s approved third party route, so if you plan to rely on an approver or a principal, ask how they support Meta campaigns before you commit.

Route: section 21 approval and approved third party status

An authorised firm with the FCA’s approver permission reviews your promotions and, if they meet the FCA’s rules, approves them. Since 7 February 2024 an authorised firm generally needs that specific permission before it can approve promotions for unauthorised businesses, with limited exceptions such as promotions within its own group or by its own appointed representatives.

• Each promotion is approved individually, and a changed promotion needs fresh approval.
• The approver has ongoing obligations. It has to monitor the promotions it approves, confirm with you at regular intervals that nothing material has changed, and report to the FCA.
• On Google, the approving firm can start the verification for you as an approved third party.

This route usually suits a business that sits outside the perimeter for what it does but whose marketing is a financial promotion. How section 21 approval works

Route: appointed representative or introducer appointed representative

An appointed representative works under an authorised principal, which takes regulatory responsibility for the activities it permits. The appointment appears on the FCA register, linked to the principal, so platforms can check it.

• A full appointed representative can carry on the regulated activities the principal is permitted to do and agrees to cover.
• An introducer appointed representative is limited to making introductions to the principal or its group and distributing certain non-real time promotions.
• Since December 2022 principals have had to assess, oversee and report on their appointed representatives more closely, so expect due diligence, ongoing monitoring and fees.

This route usually suits a business that carries on, or plans to carry on, regulated activity a principal can cover, or whose model is introducing customers to an authorised firm. It is not a way to borrow a number for a business that has nothing for the principal to oversee. Appointed representative or your own authorisation

Other routes

Some businesses need neither. If you do not promote financial services at all but your audience overlaps with people looking for them, Google’s exempt non-financial category may fit, and on Meta some brand and educational content can run without verification. If your marketing would be a financial promotion, the platform category does not change the legal position, so check that first.

How do the main routes compare?

Which route fits depends on what your business actually does, the promotions you want to run and what each platform currently accepts. That is a question for your first call, and sometimes for a written opinion.

What does not work

Using another firm’s reference number without an approval or an appointment behind it is not a shortcut. The platforms cross-check the register, the FCA treats the authorised firm as responsible for what it lends its name to, and describing your business as authorised when it is not can be a criminal offence under section 24 of FSMA. If a provider offers to “rent” you a number, ask which authorised firm is approving your promotions or appointing you, check its permissions on the FCA register and ask for the agreement in writing. It is also worth searching the FCA’s Warning List of unauthorised firms, which includes clones of genuine authorised firms.

How we help

We do not approve promotions or appoint representatives ourselves. On a short call we work out which route is likely to fit and introduce you to authorised firms that provide it: section 21 approvers for your promotions, or principals for an appointed representative arrangement through Appointed Reps. If the real question is whether you need either, we introduce you to a solicitor for a written opinion. The firms we introduce you to pay us an introduction fee. How it works