FCA publishes new webpage on risk warnings for mainstream investments
On 11 December 2025, the Financial Conduct Authority (FCA) published a new webpage setting out its expectations of firms promoting investment products, and common misconceptions about risk warnings.BackgroundThe FCA explained that it is currently supporting a review of risk warnings, led by the Investment Association and supported by HM Treasury, and that it is outlining its expectations of firms and some common misunderstandings to support this work.OverviewThe FCA set out certain considerations for firms when promoting investment products, including:
Financial promotions likely to be received by retail customers must meet requirements under the Consumer Duty. This means that they must support customer understanding, and be clear, fair and not misleading.
When designing communications, firm should put themselves in the consumer’s shoes and think about what they would want or need to know. Where appropriate, this includes testing communications.
The FCA also addressed certain misunderstandings about risk warnings, including by clarifying that:
The FCA does not prescribe risk wording for mainstream investments.
There is no requirement for mainstream investment promotions to include a separate risk warning. They must provide a balanced view of the benefits and risks, to give consumers a fair description of the product or service.
The FCA don’t mandate how firms should order their promotions. Firms may order their messaging however best supports consumer understanding.
Firms should put themselves in customer’s shoes and consider how communication’s phrasing as a whole supports’ consumer understanding.
Image advertising, such as branding, does not need information about risks.
Promotions must be standalone compliant. Firms need to ensure consumers see the right information at the right time, and are equipped to make effective, timely and properly informed decisions. This does not require generic, repeated risk disclosure on every page.
Finally, the FCA set out some it’s views on ways to meet the relevant requirements, including:
Risk statements: Firms should ensure that a financial promotion makes it clear if a product or service places a customer’s capital at risk (COBS 4.2.4G(1)). The FCA has seen firms introduce contextualised risk statements that explain both the potential benefits and risks of investing in their promotions and supports this approach.
Diminishing or disguising information: Firms should make sure promotions do not disguise, diminish or obscure important information or warnings (COBS 4.5.2R(4) or COBS 4.5A.3R(2)(e)) and must not downplay key information you provide to consumers in a way which could be misleading. That said, the FCA considered that explaining the potential benefits of a product can be done alongside explaining the risks and doing so doesn’t have to diminish the risks if done fairly, as this can be part of communicating a balanced promotion.
Cash comparisons: When communicating comparative information in relation to investments, firms must make sure that the comparison is meaningful and presented in a fair and balanced way (COBS 4.5.6R or COBS 4.5A.7R). Firms can compare cash and investment products to help a consumer’s decision-making but must provide balanced information on the features of both, and equip consumers to make effective, timely, and properly informed decisions.
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