The Financial Conduct Authority has warned that marketing, advertising and lead‑generation practices used across the claims‑management sector will come under direct scrutiny as part of a new joint review with the Ministry of Justice and the Legal Ombudsman.
The regulator said it will assess whether the “full end‑to‑end consumer journey, including lead generation, marketing and advertising, delivers good consumer outcomes.” The move signals a widening of the regulatory lens beyond case handling and fees, and into the acquisition mechanics that shape how consumers first engage with firms.
The review follows concerns about misleading or aggressive advertising, opaque sign‑up flows and the role of third‑party lead‑generation companies in driving multiple or duplicate claims. The FCA said it is seeing examples of consumers being contacted after interacting with social‑media adverts, or entering claims processes without fully understanding eligibility or fees.
For marketing and communications teams across financial services, the bulletin reinforces that marketing is now firmly part of the conduct perimeter. The FCA has already made clear under Consumer Duty that firms must evidence fair, transparent and outcome‑driven journeys; this review extends that expectation to external partners, affiliates and digital funnels.
The regulator also signalled it is prepared to escalate. If the review finds systemic issues, it may recommend legislative change to strengthen protections around advertising and lead‑gen activity. It will also work with other regulators where marketing practices overlap with broader advertising standards.
While the review is focused on CMCs, the implications reach further. Any FS brand using performance marketing, paid social, affiliate networks or third‑party lead‑gen will recognise the themes: clarity of claims, informed consent, and the need for robust oversight of acquisition channels.
The findings are expected later this year.