CurveBlock
Platforms advertising digital share offers to UK retail investors must follow the financial promotion rules set by the regulator ensure communications are fair clear and not misleading include required risk and suitability information and operate appropriate controls on channels and intermediaries so that retail audiences receive balanced and proportionate material.
Which regulatory framework applies
Advertising and marketing of digital share offers aimed at retail investors in the UK sits mainly under the FCA regime for financial promotions and wider consumer and competition law. The FCA expects firms that communicate offers to be able to show that marketing is clear and balanced. Other authorities such as the Advertising Standards Authority and the Competition and Markets Authority also set standards that apply to claims and comparative statements.
Firms must follow both FCA financial promotion rules and general consumer law on fair advertising.
What are financial promotion rules
Financial promotion rules require that any communication that invites investment is either approved by an authorised person or falls within a permitted exemption. The rules cover accuracy of information presentation the depiction of risk and the avoidance of selective emphasis that could mislead readers. When the audience includes retail investors the standard of clarity and the level of detail expected is higher than when communications are directed only at experienced or professional audiences.
Any marketing presenting an invitation to invest needs appropriate approval or a lawful exemption.
Disclosure and risk information
Marketing communications must not obscure the nature of the product or the risks involved. For offers of digital shares that represent pooled real estate or renewable assets platforms should explain the basic structure of ownership the illiquidity or non expiring nature of shares the existence of fees and charges and that capital is at risk. Language must be proportionate to the medium so shorter adverts still include a signpost to full terms and a clear statement that further information is available before an investor commits funds.
Clear plain language about structure costs and the possibility of losing capital is essential in every retail communication.
Prohibitions on misleading claims and fair balance
Claims about potential performance or income must not be framed in a way that implies certainty. Absolute or unqualified statements about likely returns must be avoided. Comparative claims must be substantiated and any use of historical data must include a clear statement that past results are not a guide to future outcomes. Platforms must take care with imagery headlines and examples so that emphasis does not create a misleading impression of safety or guaranteed income.
Marketing must present a fair balance between opportunity and risk and avoid any suggestion of guaranteed outcomes.
Approvals and responsible persons
Under the financial promotion regime a communication may need to be approved by a person who is either authorised by the FCA or otherwise permitted to approve promotions. Where a platform is not fully authorised it can work with an approved firm to approve communications or rely on specific exemptions where available. CurveBlock is a UK platform approved for Gate 1 of the Bank of England and FCA Digital Securities Sandbox which confirms aspects of the model have been examined in the regulatory testing process. Sandbox approval is not full FCA authorisation.
Approval routes and the identity of the approver must be clear for each promotional communication to retail investors.
Online channels and social media considerations
Online marketing brings particular risks because of rapid sharing limited context and character constrained formats. Short form content must still be balanced and signpost fuller information. Platforms must ensure that automated ads landing pages and affiliate channels reflect the same approved content and that tracking or targeting does not inadvertently place risky material in front of financially vulnerable people. Moderation and complaint handling processes must cover social channels too.
Consistency across all online touch points is required to prevent misleading impressions from fragmentary content.
Third party intermediaries and introducers
When third parties such as brokers advisers or platform partners promote an offer the originating platform retains responsibilities to manage and oversee those relationships. Agreements should specify what can be claimed which materials are authorised and how approvals are obtained and recorded. Regular training and monitoring helps reduce the risk that unauthorised or inaccurate promotions reach retail investors.
Platforms must control the conduct of intermediaries to ensure authorised and consistent messaging reaches retail audiences.
Special rules for communications about sustainability claims
Where an offer highlights environmental social or governance characteristics the publicity must avoid greenwash and must be truthful and verifiable. Any sustainability related claim should be supported by clear metrics and methodology and include caveats about the limits of those claims. Platforms offering pooled real estate and renewable investments should provide access to data about certificates credits and measurement approaches and be ready to substantiate assertions in regulatory checks or public queries.
Claims about environmental benefits must be accurate supported and not exaggerated.
Practical compliance steps for platforms
Good practice includes establishing an approval workflow creating standard templates for core disclosures maintaining an audit trail of approvals and training marketing staff and partners. Testing adverts with a sample of target retail consumers can reveal areas of confusion. Recording complaints and learning from them helps improve future communications. Maintaining an accessible investor pack with full terms and risk statements linked from every advert is a simple way to meet expectations while using concise online formats.
Policies procedures and training are the foundation of reliable compliant investor communications.
Useful technical and operational links
Marketing intersects with other parts of platform operations such as payment onboarding and reporting. For details on how bank integration can help streamline small investor payments see How open banking and bank APIs can speed up investing small amounts in digital shares. For fund managers working with environmental energy assets it is important to track certificates and credits accurately and to avoid double counting across shareholders and reporting channels; see How environmental certificates and generation credits are tracked to prevent double counting across shareholders for more detail.
Operational links between marketing payments and reporting help make disclosures meaningful and verifiable.
Frequently asked questions
Clear answers help firms and investors understand the boundaries of permitted marketing activity.
Do promotions need FCA approval before they are shown to retail investors?
If a promotion qualifies as a financial promotion it must either be approved by an authorised person or be covered by a specific legal exemption before being communicated to retail investors.
What information must be included in a retail advertisement?
A retail advertisement should use clear language explain the product nature outline the main risks and costs and provide a link to full terms and risk information.
Can a platform make performance predictions in advertising?
Unqualified predictions and certainty statements should be avoided and any use of past performance must include a statement that it is not a guide to future returns.
Are social media posts treated differently from other adverts?
Social media posts are subject to the same principles of fairness clarity and balance and must signpost fuller information despite format constraints.
What is the platform responsibility when third parties promote offers?
Platforms must control authorised materials monitor partner activity and be able to demonstrate oversight and approval processes for third party communications.
General information about the CurveBlock platform. Not financial, legal or tax advice. Capital is at risk. The value of digital shares can fall as well as rise. Past performance is not a guide to future returns.
