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The fintech compliance checklist for advertising

Twenty-eight checks to run before a financial services ad goes live, across the United States, the United Kingdom and four English-speaking African markets. Every line points to the regulator’s or platform’s own text, with the date we last read it.

Last checked 1 October 2026 · No email required · Free to share and cite with a link back

A checklist, not legal advice. It tells you which questions to ask and where the rule is written. Your counsel decides how it applies to your product. Where we could not source something, the cell says so rather than guessing. To run an ad’s own words against these rows, paste it into the fintech ad copy checker.


How to use it

Run it in order, one column per market you target

The checks follow the order the work happens: whether you can advertise at all, what the ad says, what the page shows, who you target, and what you keep. Read across a row for the markets you target. The numbers in square brackets are the sources at the foot of the page.

The one fact most teams miss

Nigeria pre-clears every ad

Under the ARCON Act 2022, placing an advertisement in any medium directed at the Nigerian market without prior approval of the Advertising Standards Panel is an offence, and the Act reaches foreign advertisers. The panel’s vetting guidelines list online and social media platforms. [16][17]

The one the platforms add

Google checks the UK, not the US

Google’s financial services verification covers 42 countries. The United Kingdom is one; the United States, Kenya, Nigeria, South Africa and Ghana are not. The platform rules on ad and page content still apply everywhere. [1][2]

The one that fits in no ad

A UK rate triggers eight items

A UK credit promotion that states a rate or a cost figure needs a full representative example: eight items that cannot fit in a 90-character description. So the rate usually stays out of the ad. [8][9]


Stage 1

Before the first ad: can you advertise at all?

CheckUnited StatesUnited KingdomKenya · Nigeria · South Africa · Ghana
1.1 Google financial services verificationNot in Google’s programme. Advertiser verification and the financial products policy still apply [1][3]Required. Four routes: FCA-authorised firms, approved third parties, exempt non-financial services advertisers, exempt government entities [2]None of the four is in Google’s programme. The local regulator governs the promotion [1]
1.2 If you use the FCA-authorised route—Your FRN is required, and business details and every advertised domain must match the Financial Services Register entry exactly [2]—
1.2a FCA-registered contact on the Google Ads accountUKGoogle says that “beginning September 26” — it states no year — a contact with the same email domain as the FCA-registered firm must be included in the Google Ads account before you apply for verification. A contact added from a public email domain such as gmail.com must be an identical match with the email in the FCA registration. Email-level access is enough, and the contact has to accept the invitation [2]
1.3 Meta special ad categoryThe financial products and services category is required for advertisers based in the US or showing ads to US audiences. Meta’s developer doc dates it from 14 January 2025; its Business Help Centre says 21 January 2025 [4][5]Meta states the requirement for US-based advertisers and US audiences. Check Meta’s current policy for your own market before assuming it does or does not apply [4][5]
1.4 Does the ad need approval before it runs?Not covered in this checklist’s sourcesNot covered in this checklist’s sourcesNigeria: yes, every ad, every medium, from the Advertising Standards Panel [16][17]. Kenya: securities ads and offer advertisements go to the CMA [13]. South Africa: no FSCA pre-approval; the sign-off is internal [20]. Ghana: no general regime; the SEC can direct pre-approval case by case for securities [27]
1.5 Is there an approve-on-behalf route?—At the platform layer, Google’s approved third parties route covers ads approved by an FCA-authorised firm, naming marketing agencies for lead generation [2]No equivalent found in any of the four. The gate is licensing of the firm itself
1.6 Deposit-style claims——Nigeria: only a bank or other person authorised to take deposits may advertise inviting the public to deposit money, including online. Minimum penalty ₦50m or twice the deposits collected [18]

The platform and regulator gates side by side, including Google’s crypto, CFD and debt-service certifications by market, are mapped separately.


Stage 2

The ad itself: what the words trigger

CheckUnited StatesUnited KingdomKenya · Nigeria · South Africa · Ghana
2.1 Does the ad state a rate?State it as an “annual percentage rate,” using that term (closed-end credit) [6]A rate or cost figure requires a full representative example and a postal address [9]South Africa: rate and credit costs must be stated in the prescribed manner [21]. Kenya: digital lenders may not misrepresent the interest rate, costs or charges [12]
2.2 Does it state a payment, term, down payment or finance charge?Trigger terms. Add the down payment, full repayment terms and the APR [6]A cost figure: full representative example [9]South Africa: an instalment or cost figure requires instalment amount, number of instalments, total of instalments, interest rate and residual [21]
2.3 “0%” or “no interest”Negative references trigger disclosures for open-end credit [7]Treated as a rate. No representative example where the APR is 0% [9]Not separately sourced. Treat as a rate
2.4 Incentives, comparisons, “bad credit OK”—Representative APR required, no less prominent than the claim. Speed of approval can be an incentive; a trading name or web address can trigger it [9]South Africa bans “no credit checks required”, “blacklisted consumers welcome”, “free credit”, and “pre-approved” or “loan guaranteed” unless no assessment follows [21]
2.5 APR format“Annual percentage rate” [6]Shown as “%APR”, with “representative” and, where it can change, “variable” [9]Ghana: credit solicitations state the lender’s average current APR across all active agreements for the products referenced. A portfolio average, not a representative rate [23]
2.6 Who is named in the ad?—The person making the promotion; a credit broker also names the lender where known [8]Kenya: digital lenders state they are regulated by CBK [12]. Ghana: lender’s name and a statement that it is licensed by Bank of Ghana [23]
2.7 Could the claim mislead on its own?If a necessary disclosure cannot be made clearly and conspicuously on a platform, change the claim or do not run the ad there [11]Clear, fair and not misleading; each promotion should be compliant on its own [8][10]Kenya: false or misleading representations in promotion by any means are an offence under the Competition Act s.55 [14]. South Africa: factually correct, balanced, benefits not given undue prominence over risks [20]
2.8 Responsive search adsGoogle assembles headlines and descriptions itself. Anything that must appear every time has to be pinned to Headline 1, Headline 2 or Description 1 [3a]
2.9 Self-regulatory advertising codesSouth AfricaGoogle added the Advertising Regulatory Board’s Codes of Advertising Practice to the list of self-regulatory codes it expects advertisers to follow on 22 September 2026. It sits on top of the National Credit Act and FAIS requirements, not instead of them [30]

The US and UK trigger rules are explained in full, with worked examples, in our guide to financial services advertising regulations for paid search.


Stage 3

The landing page

CheckUnited StatesUnited KingdomKenya · Nigeria · South Africa · Ghana
3.1 Google’s disclosures, visible without a click or hoverPhysical business address, all associated fees, and links to any accreditation you assert. Not in roll-over text, another tab or behind a link [3]
3.2 Personal loans on GoogleMinimum and maximum repayment period, maximum APR, representative example. Repayment of 61 days or longer only. No ads for personal loans at 36% APR or above [3]Minimum and maximum repayment period, maximum APR, representative example. Repayment of 61 days or longer only [3]
3.3 Payment and e-money providers——Ghana: all marketing material carries the provider’s address, telephone number and email [25]
3.4 Banks and deposit-takers——Ghana: only a licensed bank may use the word “bank”; a specialised deposit-taking institution uses its full licensed name in advertisements [24]

Consent timing, form language and the rest of the page as an artifact are covered in our guide to landing page compliance for fintech.


Stage 4

Targeting, retargeting and consent

CheckUnited StatesUnited KingdomKenya · Nigeria · South Africa · Ghana
4.1 Meta targeting under the special ad categoryAge fixed at 18–65+, no gender selection, no location exclusion, no lookalike audiences [4]
4.2 Calling or texting the leadsPrior express written consent before an autodialed or prerecorded call [15]—Ghana: unsolicited electronic communications need prior consent and an unsubscribe option [26]
4.3 Direct marketing and custom audiences——Kenya: express consent to use personal data commercially; showing an ad to a logged-in user counts as direct marketing; objection is absolute [19]. Nigeria: consent for direct marketing, and the Act reaches controllers outside Nigeria [22]. South Africa: electronic direct marketing prohibited without consent or a qualifying existing customer; ask for consent only once [20a]. Ghana: prior written consent [26]

Stage 5

Sign-off and records

CheckUnited StatesUnited KingdomKenya · Nigeria · South Africa · Ghana
5.1 Documented approval——South Africa: documented internal approval by a key person [20]. Ghana (securities): documented internal sign-off [27]
5.2 Keep the ads——South Africa: keep records of all advertisements for at least five years [20]
5.3 Keep an approved-wording logNot a legal requirement in our sources. Our own practice: every approved claim, its source and its approver, so the next review starts from precedent

Stage 6

Red flags: securities and crypto

CheckWhere it appliesWhat the source says
6.1 Securities adsNigeriaNo advertisement inviting subscription for securities without prior SEC approval, including on electronic media [28]
6.2 Marketing securities unlicensedKenyaNo person may market securities by advertisement unless licensed [13]
6.3 Crypto is a financial productSouth AfricaDeclared a financial product from 19 October 2022, so crypto marketing sits inside the advice and intermediary rules [20b]
6.4 Crypto mass marketingGhanaBank of Ghana and the SEC directed virtual asset providers on 20 February 2026 to stop mass marketing unless authorised, and to take public advertising down within 48 hours [29]
6.5 Crypto advertising rulesKenyaIn force since 22 July 2026. Nobody may advertise or promote a virtual asset service, including initial coin offerings and non-fungible tokens, unless they comply with Part XIII of the Virtual Asset Service Providers Regulations, 2026. An advertisement must be fair, clear and not misleading; carry the licensee’s full name, licence number and registered office; give a fair and balanced indication of the risks whenever it references benefits; state the service offered, the deposit and withdrawal terms and timeframes, the fees payable and where full terms can be read; and advise the consumer to do their own research. Past performance needs a clear and prominent statement that it does not indicate future performance. There is no pre-approval — the regulator does not vet the advertisement — but records of each advertisement and who signed it off are kept for at least seven years, and a third party paid to promote must disclose that they are paid [31]

Investment promotions in the UK are governed by a different sourcebook from credit and are not covered line by line here.


Next

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Sources

Every row, and when we read it

  1. Google Advertising Policies Help, Relevant regulators and enforcement dates (42 countries) — support.google.com/adspolicy/answer/12390454 — checked 1 October 2026
  2. Google Advertising Policies Help, Financial Services Verification, United Kingdom location view — support.google.com/adspolicy/answer/15332527 (United Kingdom) — checked 1 October 2026
  3. Google Advertising Policies Help, Financial products and services — support.google.com/adspolicy/answer/2464998 — checked 21 September 2026. [3a] Google Ads Help, About responsive search ads — support.google.com/google-ads/answer/7684791 — checked 21 September 2026
  4. Meta for Developers, Special Ad Category — developers.facebook.com/documentation/ads-commerce/marketing-api/audiences/special-ad-category — checked 20 September 2026
  5. Meta Business Help Centre, How to choose a Special Ad Category — facebook.com/business/help/298000447747885 — checked 20 September 2026
  6. CFPB, Regulation Z §1026.24 Advertising, with official interpretation — consumerfinance.gov/rules-policy/regulations/1026/24 — checked 21 September 2026
  7. CFPB, Regulation Z §1026.16 Advertising (open-end credit) — consumerfinance.gov/rules-policy/regulations/1026/16 — checked 21 September 2026
  8. FCA Handbook, CONC 3.3 — handbook.fca.org.uk/handbook/CONC/3/3.html — checked 21 September 2026
  9. FCA Handbook, CONC 3.5 (3.5.3R, 3.5.4G, 3.5.5R, 3.5.7R, 3.5.8G, 3.5.9R) — handbook.fca.org.uk/handbook/CONC/3/5.html — checked 21 September 2026
  10. FCA, FG24/1 Finalised guidance on financial promotions on social media, March 2024, para 2.20 — fca.org.uk/publication/finalised-guidance/fg24-1.pdf — checked 21 September 2026
  11. FTC, .com Disclosures: How to Make Effective Disclosures in Digital Advertising, March 2013 — ftc.gov/business-guidance/resources/com-disclosures — checked 21 September 2026
  12. CBK (Digital Credit Providers) Regulations 2022, Legal Notice 46, gazetted 18 March 2022, regs 25(d) and 28 — centralbank.go.ke — checked 21 September 2026
  13. Capital Markets (Licensing Requirements) (General) Regulations 2002, LN 125, regs 56 and 63(7); Public Offers, Listings and Disclosures Regulations 2023, LN 172, reg 28(2) — kenyalaw.org LN 125 · kenyalaw.org LN 172 — checked 20 September 2026
  14. Kenya Competition Act 2010, s.55 — kenyalaw.org — checked 20 September 2026
  15. 47 CFR 64.1200 — ecfr.gov — checked 20 September 2026
  16. Advertising Regulatory Council of Nigeria Act 2022, ss.54 and 63 — placng.org — checked 21 September 2026
  17. ARCON Advertising Standards Panel Vetting Guidelines, dated 1 January 2023 — advertcouncil.gov.ng — checked 21 September 2026
  18. Banks and Other Financial Institutions Act 2020 (Nigeria), s.44 — quoted in our regulator research of 20 September 2026; we found no stable official URL to link
  19. Kenya Data Protection Act 2019, s.37; Data Protection (General) Regulations 2021, LN 263, regs 8(4) and 14(2) — odpc.go.ke — checked 21 September 2026
  20. FAIS General Code of Conduct, s.14 as substituted by Board Notice 706 of 2020, in effect from 26 December 2020 — gov.za — checked 21 September 2026. [20a] POPIA s.69 — checked 20 September 2026. [20b] General Notice 1350 of 2022 — checked 20 September 2026
  21. National Credit Act 34 of 2005, s.76; National Credit Regulations 2006, reg 21(3), (6) and (8) — checked 20 September 2026
  22. Nigeria Data Protection Act 2023, s.2(2)(c); NDPC General Application and Implementation Directive, March 2025, art 18(1)(a) — ndpc.gov.ng — checked 20 September 2026
  23. Bank of Ghana, Disclosure and Product Transparency Rules for Credit Products and Services, 2017, rule 25(ii) — archived copy of BoG’s file (bog.gov.gh was unreachable on both dates we checked) — checked 21 September 2026
  24. Ghana Banks and Specialised Deposit-Taking Institutions Act 2016 (Act 930), ss.18 and 23; Securities Industry Act 2016 (Act 929) — checked 20 September 2026
  25. Ghana Payment Systems and Services Act 2019 (Act 987), s.45(6) — ghalii.org — checked 20 September 2026
  26. Ghana Data Protection Act 2012 (Act 843), s.40(1); Electronic Transactions Act 2008 (Act 772), s.50 — checked 20 September 2026
  27. SEC Ghana, Securities Industry (Conduct of Business) Guidelines 2020, guideline 29 — sec.gov.gh — checked 20 September 2026
  28. Nigeria Investments and Securities Act 2025, s.103 — sec.gov.ng — checked 20 September 2026
  29. Bank of Ghana and SEC Ghana, Public Notice on Unauthorised Advertising of Virtual Asset and Stablecoin Products, 20 February 2026 — archived copy of BoG’s file — checked 20 September 2026
  30. Google Advertising Policies Help, Update to Legal Requirements Policy (September 2026), posted 22 September 2026 — support.google.com/adspolicy/answer/17597473, and List of advertising codes — support.google.com/adspolicy/answer/11108174 — both checked 1 October 2026
  31. The Virtual Asset Service Providers Regulations, 2026 (Legal Notice 134 of 2026, 22 July 2026), Part XIII, regulations 123 to 133, made under the Virtual Asset Service Providers Act (No. 20 of 2025) — new.kenyalaw.org — checked 1 October 2026

Found something out of date? Tell us at administrator@momentumadworks.net and we will correct it and date the change. The rules move; our fortnightly newsletter, Regulated Growth, covers what changed.