Free resource · US · UK · Kenya · Nigeria · South Africa · Ghana
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
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.
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]
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]
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
| Check | United States | United Kingdom | Kenya · Nigeria · South Africa · Ghana |
|---|---|---|---|
| 1.1 Google financial services verification | Not 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 account | UK | Google 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 category | The 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 sources | Not covered in this checklist’s sources | Nigeria: 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
| Check | United States | United Kingdom | Kenya · 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 ads | Google 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 codes | South Africa | Google 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
| Check | United States | United Kingdom | Kenya · Nigeria · South Africa · Ghana |
|---|---|---|---|
| 3.1 Google’s disclosures, visible without a click or hover | Physical 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 Google | Minimum 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
| Check | United States | United Kingdom | Kenya · Nigeria · South Africa · Ghana |
|---|---|---|---|
| 4.1 Meta targeting under the special ad category | Age fixed at 18–65+, no gender selection, no location exclusion, no lookalike audiences [4] | ||
| 4.2 Calling or texting the leads | Prior 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
| Check | United States | United Kingdom | Kenya · 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 log | Not 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
| Check | Where it applies | What the source says |
|---|---|---|
| 6.1 Securities ads | Nigeria | No advertisement inviting subscription for securities without prior SEC approval, including on electronic media [28] |
| 6.2 Marketing securities unlicensed | Kenya | No person may market securities by advertisement unless licensed [13] |
| 6.3 Crypto is a financial product | South Africa | Declared a financial product from 19 October 2022, so crypto marketing sits inside the advice and intermediary rules [20b] |
| 6.4 Crypto mass marketing | Ghana | Bank 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 rules | Kenya | In 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
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.