Can financial advisers use LinkedIn under FCA rules?

For UK financial advisers, IFAs and wealth managers who want to post on LinkedIn and stay inside FCA rules. Every answer links to the rule or guidance behind it, so you and your compliance team can check the source.

Can financial advisers use LinkedIn under FCA rules?

Yes. The FCA says its financial promotion rules are technology neutral and apply across every channel used to advertise, including social media. So a LinkedIn post is judged the same way as a printed advert or an email. What matters is what each post says: if it invites or persuades people to invest, the promotion rules apply.

The FCA set out its expectations in FG24/1, its finalised guidance on financial promotions on social media, first published on 26 March 2024. It replaced the older FG15/4 guidance on social media and customer communications. It covers authorised firms, and unauthorised people such as influencers who promote financial products.

Three points from the FG24/1 document matter most on LinkedIn:

• Each post has to comply on its own. A link to a fuller page can add detail, but the post itself must still be compliant (paragraphs 2.20 and 2.21).
• Information that must be prominent shouldn’t be hidden behind a “see more” cut-off. Where possible, it should show without the reader clicking to expand the text (paragraphs 2.28 and 2.29).
• The Consumer Duty applies to promotions likely to reach retail customers, on social media as anywhere else (paragraph 2.12).

If you work for a firm, read its social media policy before you post from your personal profile.

Does a LinkedIn post count as a financial promotion?

It can. A financial promotion is an invitation or inducement to engage in investment activity, made in the course of business. FG24/1 says any communication, including a social media post, can be one. The FCA’s perimeter guidance treats an advert that only says you offer investment services as an inducement to make contact, not to invest.

The FCA uses an objective test. Would a reasonable observer see the post as trying to persuade or incite the reader to engage in investment activity? A communication with no element of persuasion or incitement is not an invitation or inducement (PERG 8.4.4G).

PERG 8.4.7G gives two examples from opposite ends:

• An advert that only holds you out as having expertise in, or providing, investment management is an inducement to make contact, not to invest.
• An advert telling the reader that investing is how to make their fortune, and that you can help them do it, is an inducement to invest.

Image advertising is lighter touch. A post showing only your firm’s name, logo, contact point and the types of product or service you offer, or your fees, is likely to be exempt from many of the rules. It may not be a promotion at all (FG24/1, paragraph 2.14).

Sharing counts as well. If your firm reposts a client’s post and it amounts to a promotion, your firm is responsible for it, even though it didn’t write it (FG24/1, paragraph 3.11).

Do my LinkedIn posts need compliance sign-off?

Posts that are financial promotions do. FG24/1 says firms must have an adequate system to sign off digital media communications, in line with SYSC 3 and SYSC 4. The person signing off should have appropriate competence and seniority. Your firm’s own social media policy may ask to see other posts too.

FG24/1 says the Handbook’s sign-off and record-keeping rules apply to social media in the same way as to print, broadcast and outdoor media (paragraphs 3.15 to 3.17). COBS 4.10.1G points to the same SYSC rules for any firm that communicates or approves a financial promotion.

A routine that makes sign-off easier:

• Draft posts a week ahead, so compliance can review them in one batch.
• Publish the approved version as it is. If you change a word, send it back for review.
• Take the same care with comments and replies. Any form of communication can be a promotion (FG24/1, paragraph 2.8), so a reply that pushes a product needs review too.

If OwnDesk writes your posts, you or your compliance team approve each one before it goes out.

Do I need to keep records of my LinkedIn posts?

Yes, for posts that are financial promotions. COBS 4.11.1R says a firm must make an adequate record of any financial promotion it communicates or approves. How long you keep it depends on the product. FG24/1 adds that firms shouldn’t rely on the platform to hold their records, because social media sites can delete older material.

The retention periods in COBS 4.11.1R are:

• Pension transfers, pension conversions, pension opt-outs and FSAVCs: indefinitely.
• Life policies, occupational pension schemes, SSASs, personal pensions and stakeholder pensions: six years.
• MiFID or equivalent third country business: five years.
• Any other case: three years.

COBS 4.11.2G also suggests recording why you were satisfied that the promotion complied. More widely, SYSC 9.1.1R requires orderly records that let the FCA monitor your compliance.

In practice, log a copy of each approved post, the date it went out, who signed it off and the link. LinkedIn’s data download includes all your shared or re-shared posts with their dates and URLs. That helps you check your own log is complete.

What should financial advisers post on LinkedIn?

Post answers to the questions your clients already ask you, in plain English. Explain rule changes, deadlines and how your service works, and share your view on the news without predicting returns. These posts show how you think without pushing a product. Anything that names a product, shows performance or promises an outcome needs extra care and sign-off.

Ideas to start with:

• A question from a client meeting, with names and details removed.
• What a first meeting with you looks like, and what to bring.
• A rule change explained, with a link to the official source on gov.uk or the FCA site.
• A mistake you often see people make, and what you’d check instead.

Things to handle with care:

• Past performance. COBS 4.6.2R says it can’t be the most prominent feature. It must cover the past five years in complete 12-month periods, or the whole period if shorter. It must state the source and period, and carry a prominent warning that past performance is not a reliable indicator of future results.
• Words like “guaranteed”, “protected” or “secure”. COBS 4.2.5G says to avoid them unless they are a fair, clear and not misleading description and you give all the information needed with enough clarity and prominence.
• Risks tucked away. FG24/1 says putting the benefits in an image or video and the risks only in the caption doesn’t give risk enough prominence (paragraph 2.27).

How often should a financial adviser post on LinkedIn?

Pick a number you can keep up every week, with time for compliance to review each post. LinkedIn’s best practices for company Pages say companies that post weekly see a 2x lift in engagement with their content. FG24/1 sets no posting limit, but it warns against bombarding people with promotions.

The figure comes from LinkedIn’s Pages best practices, so it’s about company Pages rather than personal profiles. It still points the same way: post regularly.

On the FCA side, FG24/1 says the regulator has seen consumers “repeatedly bombarded by financial promotions from the same service or firm”. It doesn’t see that as acting in good faith under the Consumer Duty (paragraph 3.5). So let most posts explain and inform, and keep promotions occasional.

If writing is what holds you back, OwnDesk writes one post every weekday for £250 a month, or two every weekday for £350. The posts are written from your answers to weekly questions, sent by text or voice note.

How do wealth managers get clients from LinkedIn?

Through posts and one-to-one conversations together. Posts make your name familiar to the people you want to reach. Messages do the rest: send each one by hand to someone you have a real reason to contact, and ask for a call rather than pitching a product. Every message still has to meet FCA and privacy rules.

What that looks like in practice:

• Make your headline say who you help, not only your job title.
• Send connection requests to people you have a link with. LinkedIn recommends inviting only people you know and trust. Its invitation limits exist “to prevent misuse and promote thoughtful networking”, and a restriction typically lasts one week (LinkedIn Help).
• Send each message by hand. The LinkedIn User Agreement (section 8.2) bans bots and other unauthorised automated methods used to add contacts, send messages, or like and comment on posts.
• Check privacy rules. The ICO says its electronic mail marketing rules apply to direct messages via social media too. You can’t send marketing to individuals without their specific consent, apart from the soft opt-in for previous customers. Companies are treated differently. The ICO notes the guidance is under review after the Data (Use and Access) Act.
• If you follow up by phone, remember that a follow or a like doesn’t count as an established existing client relationship under the FCA’s cold-call rules (FG24/1, paragraph 3.13).

OwnDesk’s LinkedIn outreach is sent by hand, with no automation tools.

Sources

• FCA, FG24/1: Finalised guidance on financial promotions on social media (web page)
• FCA, FG24/1 full guidance (PDF)
• FCA Handbook, PERG 8.4: Invitation or inducement
• 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 4.10: Approving and confirming compliance of financial promotions
• FCA Handbook, COBS 4.11: Record keeping, financial promotion
• FCA Handbook, SYSC 9.1: General rules on record-keeping
• ICO, Electronic mail marketing
• LinkedIn User Agreement
• LinkedIn Help, Invitation limit reached
• LinkedIn Help, Download your data
• LinkedIn, LinkedIn Pages best practices

Want your posts written and ready for sign-off? See our LinkedIn packages.