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September 24, 2026

FCA Puts Financial Promotion Rules Under Review After Finding Just 6% of Investment Disclosures Are in Plain English

Greater plain-language disclosures are a cornerstone for the UK’s investment culture to flourish, at a time where illicit promotions are being targeted.

Greater plain-language disclosures are a cornerstone for the UK’s investment culture to flourish, at a time where illicit promotions are being targeted.

TL;DR: assess your fund content’s readability scores.

Readability scores are paramount for bettering an investor’s understanding of what is presented to them. This relates to all investment content: email newsletters, factsheets, in-depth reports, CEO letters, and most importantly, fund disclosures.

It turns out that the UK’s investments industry has a readability problem. The Financial Conduct Authority’s Director of Consumer Investments Lucy Castledine said as much at London’s 2026 Investor Summit, where analysis using the Flesch-Kincaid readability score found only 6% of pre-sales disclosure documents were written in plain English.

This finding justifies reforms that the FCA has already put into action: a review of fund promotion rules to check if they push firms toward defensive, jargon-filled risk warnings, rather than messaging that helps retail investors’ allocation decisions.

The new Consumer Composite Investments regime, launched in April, looks to replace prescriptive, PRIIPS-style templates with product information designed by firms themselves.
That way, they have greater means to explain risk, reward and fees in informative language that does not confuse investors. The regime has already been adopted by nine firms.

As early evidence that plainer engagement can move money from into markets without full advice, the FCA also reported a 33% hike in investment account openings from Monzo customers who received investment nudges.

This also arrives in the midst of a growing ‘underbelly’ for illicit financial promotions. Castledine pointed to the FCA’s now-systemic crackdown on unlawful fund promoters (including “finfluencers”), finding 48 alerts against unauthorised UK firms and 120 social takedown requests. Ofcom and tech platforms have been charged with moving quicker to stop fraudulent financial advertising and deepfakes (both growing under sophisticated GenAI tool development) with a consultation deadline of 2 October.

Castledine’s speech then placed more pressure on unregulated high-risk products, including the FCA’s warning on minibonds and loan notes sold to retail investors outside the regulatory perimeter, and asked the government to revisit their exemption that allows this.

So, what does this mean for fund marketers?

With financial promotion rules under actual live review, firms that market in the UK will likely have to adhere to proper changes rather than shifting their interpretation of existing legislation.
The 6% Flesch-Kincaid result makes readability a documented regulatory concern that all UK-facing factsheets or pitch decks cannot afford to fail. Elsewhere, any affiliate marketing or paid social promotion for investors should be audited before any takedown occurs without a fund being notified.

Then again, there are also opportunities for funds in light of this call for transparency. Firms have a rare window to submit evidence of helpful risk warning language before new rules get drafted, for one. Similarly, the FCA-approved citation of Monzo’s engagement boost highlights that well-evidenced nudge-based marketing can be compliant, as well as critical to raising assets. So while operating under Consumer Duty guardrails may feel a hindrance, it may in fact prove the opposite!

Source
FCA, “Building a stronger UK investment culture”

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