Generative AI has made it easy to produce marketing copy in seconds: website pages, social posts, emails and newsletters. For an FCA-authorised firm that speed comes with a catch. The rules do not care how the copy was written. If it promotes your services, it is a financial promotion, and the firm is responsible for it.
This guide covers why AI-drafted copy needs the same scrutiny as anything else, where it tends to go wrong, and a practical review process. It is not compliance advice; your compliance function or network has the final word.
Every word is still a financial promotion
The FCA is clear that "all financial promotions must be clear, fair and not misleading regardless of the media type", and that promotions "can take the form of a website, Facebook post, tweet, etc." See the FCA's financial promotions page and its guidance on social media promotions.
So a blog post drafted by an AI tool, an email sequence written with a chatbot, or a LinkedIn post generated from a prompt all carry the same obligations as copy written by hand. Responsibility sits with the firm, not the software.
Where AI copy tends to go wrong
AI tools are trained to write persuasively, and persuasive is not the same as compliant. The common problems are predictable.
Overconfident claims
AI copy reaches for phrases such as "secure your financial future", "grow your wealth" or "guaranteed peace of mind". Claims that imply outcomes, certainty or protection the firm cannot deliver are exactly what the clear, fair and not misleading standard is designed to catch.
Missing balance and risk information
Copy that mentions benefits of investing or pension planning without the corresponding risks is unbalanced. AI tools rarely add risk warnings unless asked, and when they do the wording may not be what your firm or network requires.
Invented facts and figures
AI tools can produce plausible statistics, quotes and references that do not exist. Any figure in a promotion must be accurate and traceable. If you cannot find the original source, delete the figure.
Wrong jurisdiction
Many tools default to US terminology and products: 401(k)s, fiduciaries, IRAs. Copy that reads as American undermines trust and can describe things that do not apply in the UK.
Implied advice
General marketing can drift into something that reads like a personal recommendation, such as "if you are over 55 you should consider drawdown". That is the line between promotion and advice, and AI does not reliably respect it.
Consumer Duty
The Consumer Duty asks firms to communicate in a way that supports customer understanding. Long, jargon-heavy or emotionally loaded AI copy can fail that test even when nothing in it is strictly false.
A review process that works
AI can still save a great deal of time, provided it is treated as a drafting assistant rather than an author.
- Brief it properly. Give the tool your firm's proposition, target client, approved terminology and banned phrases. Tell it to write in UK English and avoid promises about outcomes.
- Draft, then edit as a person. Rewrite anything that does not sound like your firm. Remove anything you would not say to a client face to face.
- Check every fact. Each figure, rule, date or allowance should be checked against a primary source such as gov.uk, the FCA or HMRC, and the source kept on file.
- Add the required information. Risk warnings, status disclosures and anything your network requires.
- Submit for approval. Send it through your normal compliance sign-off, with a note that AI was used in drafting if your firm's policy asks for it.
- Keep a record. Store the approved version and the date it went live, so you can show what was published and when.
Common questions
Do we have to tell clients that AI wrote our marketing?
There is no general FCA rule requiring firms to label AI-drafted marketing. What matters is that the content is clear, fair and not misleading and approved like any other promotion. Your firm or network may have its own policy on disclosing AI use, so check it.
Can AI write our social media posts?
AI can draft them, but social media posts are financial promotions and the FCA has specific guidance on them. Each post still needs human review, appropriate risk information where required, and approval under your normal process. Short formats make balance harder, not optional.
Who is responsible if AI copy breaks the rules?
The authorised firm. Using a tool or an agency to draft marketing does not move responsibility for the promotion. That is why the review and approval steps matter more, not less, when copy can be produced quickly.
Build compliance into the website itself
Much of this gets easier when the website is designed for it. Templates that add the right risk warnings automatically, a content system with an approval step before anything goes live, and a record of approved versions turn compliance from a late rewrite into a routine check. We cover this in more detail on our financial services web design page.
Where AI helps most safely
The lower-risk uses of AI in a firm's marketing tend to be:
- turning an adviser's own notes or recorded explanation into a first draft
- summarising a regulatory change from a primary source for internal use
- suggesting headlines and structure for a post you will write yourself
- acknowledging and routing website enquiries, without discussing a client's circumstances
The higher-risk uses are anything published without human review, anything that comments on an individual's situation, and anything containing figures you have not checked.
If you are building marketing systems around AI and want them designed with compliance in mind, see AI for financial advisors or book a call.