FCA Rules for Adviser Websites: What Your Site Must Show, and What It Can’t Say

When we build homepage prototypes for IFAs and mortgage brokers, compliance is the first question we’re asked. It’s often the reason a refresh has been put off for years. The rules are less mysterious than they look: a handful of FCA Handbook provisions do most of the work, and almost all of them can be designed into the page rather than bolted on at the end.

This guide is for directly authorised advice firms and mortgage brokers in the UK. If you’re an appointed representative, your network or principal will usually have its own sign-off process and house rules, so treat this as background and check with them.

One caveat up front. Heer Digital is a web design agency, not a compliance consultancy. This article explains where the rules meet design decisions, with links to the rule text behind each point. Sign-off on your own site should still come from your compliance function or adviser.

Your website is a financial promotion

If your website invites people to use your advice or mortgage services, the FCA treats it as a financial promotion, and the conduct rules for communicating with clients apply to it. That covers your homepage, service pages, blog posts that lead to an enquiry, and anything you push out on social media.

In practice that means every claim on the site has to meet the same standard as a printed advert or a client letter. The rest of this guide covers what that standard is, what has to be on the page, and where adviser sites most often fall short.

The core test: fair, clear and not misleading

Everything on the site has to pass one test, set out in COBS 4.2.1R: communications and financial promotions must be fair, clear and not misleading. The FCA judges the overall impression a page gives, so a careful footnote doesn’t rescue a headline that overpromises.

Three parts of COBS 4.2 catch adviser sites most often:

• Balance between benefits and risks. If a page sells a benefit, the relevant risk or limitation has to be visible near it, at comparable prominence. In its March 2026 review of consumer understanding, the FCA criticised risk warnings set in small or low-contrast type, and warnings placed at the end of long mobile journeys. Both are design decisions.
• Words with special conditions. COBS 4.2.5R restricts describing anything as “guaranteed”, “protected” or “secure”. Those words turn up in hero copy more often than you’d expect, usually as “secure your retirement”.
• Mixing regulated and unregulated services. Under the COBS 4.2.4G guidance, if your site names the FCA as your regulator and also promotes something it doesn’t regulate, you need to make that distinction clear. For advisers this is usually will writing or estate planning referrals; for brokers, commercial or some buy-to-let lending.

What has to be on the page

A handful of disclosures come from law or FCA rules rather than taste. The simplest way to never miss them is to build them into the site footer and page templates, so no new page can go live without them.

Two of these deserve a second look on most sites.

The FRN link. Visitors increasingly check firms on the FCA Register because of clone-firm scams. Linking the number straight to your Register entry turns a compliance line into a trust signal. [Add: whether the adviser sites you’ve reviewed tend to do this.]

“Independent” in places nobody checks. Firms often fix the About page but leave “independent financial adviser” in the page title, the meta description, or a Google Business Profile. Those are what people see in search results, so they count.

Where adviser sites go wrong

These are the patterns we run into most when we rebuild an IFA or broker homepage as a prototype. None of them is deliberate. They build up as a site is edited over the years by different people.

1. A headline that promises an outcome. “Maximise your retirement income” or “Secure your family’s future” reads as a promise of a result. A headline about what you do and who you do it for carries the same weight without the risk.
2. Disclosures exiled to the footer in tiny grey type. It’s technically present and practically invisible, which is exactly what the FCA’s 2026 review criticised. Footer text is fine for status lines; warnings belong beside the claim they qualify, at a readable size and contrast.
3. Performance figures without the conditions. Past performance is allowed, but under COBS 4.6 it can’t be the most prominent feature, should cover the previous five years where available, and needs a prominent warning that it isn’t a reliable indicator of future results.
4. Calculators with hidden assumptions. An affordability or pension calculator that shows a single number, with no rate, term or assumption beside it, is a promotion in its own right. Show the assumptions and say the result is illustrative.
5. Blog posts that drift into advice. “Now is the time to fix” reads as a recommendation to everyone. General guidance stays general; anything that sounds personal should end in an invitation to talk.
6. Content that has gone out of date. Tax-year figures, allowances and rate examples become misleading simply by ageing. A two-year-old article quoting the old pension rules is a live compliance problem, not just a stale page.

[Add one anonymised before-and-after from a recent prototype: the original line, what was wrong with it, and how the prototype handled it. A screenshot of the two side by side would be stronger still.]

Testimonials and reviews

The FCA doesn’t ban testimonials. But a client quote on your site is a communication from your firm, so it has to meet the same fair, clear and not misleading standard as everything else you publish.

In practice that gives four working rules:

• Quote the experience, not the result. “David explained everything clearly and never rushed us” is safe. “Our pension grew 12% a year” is a performance claim you’d need to substantiate, with all the conditions above. When you ask clients for reviews, ask about clarity and the process rather than returns.
• Don’t curate a false picture. Showing only glowing reviews, or trimming a quote so it says more than the client meant, can mislead even if every word is genuine. Many review widgets let you hide anything below five stars. If yours is set that way, think about whether the page still gives a fair impression.
• Never write or incentivise reviews you don’t disclose. Since 6 April 2025, fake reviews and concealed incentivised reviews have been banned outright under consumer law, with fines of up to 10% of global turnover (summary).
• Verified platforms help, but don’t transfer responsibility. VouchedFor, Unbiased and Google reviews add independent verification, which makes them stronger evidence than quotes you host yourself. How you select and present them is still your responsibility. We cover the platforms in more detail in VouchedFor, Unbiased and Google Reviews: Turning Your Website Into a Trust-Building Machine.

Several broker sites we’ve looked at recently pull Google reviews through free third-party widgets. They’re a quick win, but check two things: what the widget’s filter settings hide, and whether its free-tier branding looks out of place on a regulated firm’s homepage.

Consumer Duty: being understood, not just accurate

The Consumer Duty, in force since 31 July 2023, raised the bar from “accurate” to “understood”. Its consumer understanding outcome (PRIN 2A.5) expects your communications to help customers make informed decisions, taking account of who they are, including customers in vulnerable circumstances.

For a website, the FCA’s March 2026 review of 38 firms is the most practical guide to what that means. What it praised:

• Putting essential information first, with detail layered underneath
• Better colour contrast, meaningful image alt text, and layouts tested with screen readers
• Testing pages with analytics, A/B tests and short comprehension checks, and recording what changed and why

What it criticised:

• Changing wording, icons or colours without fixing the order and prominence of key information
• Treating an absence of complaints as proof that customers understood
• Promotions that highlighted the benefit and hid the limits

A cheap way to start: ask three people who aren’t clients to read your homepage and explain back what you do, what it costs and what the risks are. Where they stumble is where the page needs work.

Accessibility is the other half of this, especially for firms whose clients skew older. We cover it in Your Website Is a Consumer Duty Problem.

A compliance checklist for your website refresh

Work through this before a new site goes live, and again whenever a major page changes.

• Firm name, address, email, FCA status wording and FRN in the footer of every page
• FRN linked to your FCA Register entry
• Company number and registered office in the footer, if you’re a limited company
• “Independent” used only if you give independent advice, including in page titles and meta descriptions
• No headline promising an outcome; no “guaranteed”, “protected” or “secure” without checking COBS 4.2.5R
• Risk warnings beside the claims they qualify, at a readable size and contrast on mobile
• Mortgage repossession warning beside every mortgage promotion
• Unregulated services, such as wills, clearly labelled as not regulated by the FCA
• Past performance shown only with the COBS 4.6 conditions, or not at all
• Calculators show their assumptions and say the result is illustrative
• Testimonials about experience rather than returns; review widgets not filtered to mislead
• Complaints page linked from the footer, mentioning the Financial Ombudsman Service
• Blog posts checked for out-of-date figures and rules
• Social posts that promote your services held to the same standard (FCA FG24/1)
• Homepage read back by three non-clients, and the results noted
• A named person signs off every new page before it’s published

Building compliance in, not bolting it on

The expensive version of compliance is a finished site that gets marked up at the end and partly rebuilt. The cheap version is deciding where disclosures and warnings live before anything is designed.

That’s how we approach adviser sites:

1. Discovery. A recorded briefing call, using a structured questionnaire, covers your permissions, whether you’re independent or restricted, which services are regulated, and who signs off content.
2. Prototype. We build a working homepage prototype with the disclosures and warnings already in place, so you see the real page rather than a mock-up with “legal text here”.
3. Review. You and your compliance adviser comment directly on the prototype, element by element, and we action each comment.
4. Build. In the finished WordPress site, footer disclosures are set once for the whole site, so a new page can’t go live without them.

If you’d like to see what that looks like for your firm, we’ll build a working prototype of your new homepage at no cost. You can put it in front of your compliance adviser before committing to anything.

If you’re weighing up what kind of site you need, No CMS or Full WordPress? covers the options. And if you’re directly authorised, Directly Authorised and Invisible explains how to make that status work harder on the page.

About the author

David Dawkins is the founder and director of Heer Digital. Before founding Heer in 2012, he worked in marketing and product management in regulated financial services at GE Capital, GE Money, GMAC-RFC and the AA. He now leads Heer’s website work for IFAs and mortgage brokers. Connect on LinkedIn.

This article is general information about how FCA rules affect website design. It isn’t legal or compliance advice.

Sources

• FCA Handbook, COBS 4.2: Fair, clear and not misleading communications
• FCA Handbook, COBS 4.6: Past, simulated past and future performance
• FCA Handbook, COBS 6.2B: Describing advice services
• FCA Handbook, GEN 4: Statutory status disclosure
• FCA Handbook, PRIN 2A.5: Consumer Duty, consumer understanding
• FCA: Consumer understanding, good practice and areas for improvement (March 2026)
• FCA FG24/1: Financial promotions on social media
• Electronic Commerce (EC Directive) Regulations 2002, regulation 6