Category: Compliance & AML · Reviewed by Amy Price, Account Executive · Last reviewed June 2026
The FCA rule requiring authorised firms to keep records of every financial promotion they communicate or approve, including how it was approved, who approved it, when, and the underlying evidence relied on.
COBS 4.11 sets out the record-keeping rules for financial promotions. A firm must keep a written log of each promotion (or representative copy where bulk variations are issued), the approver, the date of approval, the channel, and the supporting evidence such as performance data or factual back-up. The record must be retained for at least five years (six years for MiFID business) and longer where other rules require.
FCA Handbook, COBS 4.11.1R. Made under FSMA sections 137A, 137R and 138. The retention period reflects the MiFID II Article 16(6) requirement (six years) for MiFID business and the FCA’s general three-to-five-year period for non-MiFID business.
The “promotions log” is typically a spreadsheet or compliance system entry. For each promotion the log records: the date, the title or reference, the channel (web, email, social, print, broadcast), the audience type (retail / professional), the regulated activity or product, the approving SMF or delegated approver, the sign-off date, the version history, and the evidence files. For social media in particular, the FCA’s FG24/1 guidance on financial promotions on social media gives further direction on capture, archival and influencer arrangements.
For insurance distribution the substantively equivalent record-keeping requirement runs through ICOBS 4 and the general SYSC 9 record-keeping duty. The Consumer Duty introduces an additional layer — firms must be able to evidence that promotional communications support good outcomes and consumer understanding.
A LinkedIn campaign promoting a commercial property insurance product is logged with the date of approval, the SMF holder who approved (or the delegated compliance officer), the version of the creative, the source of any statistics used, the audience targeting parameters and the evidence demonstrating the headline claim. The campaign post is captured as a PDF and saved in the promotions library.
FCA Handbook, COBS 4.11.1R. Financial Services and Markets Act 2000, sections 137A, 137R, 138. FCA Finalised Guidance FG24/1 (Financial promotions on social media). UK retained MiFID II (Directive 2014/65/EU), Article 16(6).
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
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