Debt Advice and Credit Brokers: FCA Permissions and Website Claims

A website for a debt adviser or credit broker does two jobs at once. It explains a service to someone who is often anxious, and it is a financial promotion in the eyes of the Financial Conduct Authority (FCA). That second job comes with rules that decide what you can say, what you must say, and who is allowed to approve the words.

The starting point is section 21 of the Financial Services and Markets Act 2000. The FCA's 2022 Dear CEO letter to credit brokers puts it plainly: it is unlawful for a person in the course of business to communicate a financial promotion unless that person is authorised, the content has been approved by an authorised person, or an exemption applies. For a debt or credit business, the practical question is therefore always whether your firm holds the right permission, and whether the page you are about to publish matches it.

This guide is for small firms and the people who build their sites. It explains how the FCA treats debt counselling, debt adjusting and credit broking, what must appear in a credit broker's promotions, how fees must be presented, and the checks a page should pass before it goes live. It is not legal advice, and it describes the rules as published on the FCA pages cited at the end.

The FCA's Perimeter Guidance explains that the regulated activities specifically relating to consumer credit debt counselling are in article 39E of the Regulated Activities Order. They are giving advice to a borrower about the liquidation of a debt due under a credit agreement, and giving advice to a hirer about the liquidation of a debt due under a consumer hire agreement.

Three points in that guidance catch website writers out.

• Advice, not information. Debt counselling covers the giving of advice. It does not cover just giving mere information. A page that explains what a debt relief order is, in neutral terms, differs from a page that tells a visitor which solution to take.
• Liquidation is wide. The guidance says liquidation of a debt covers paying it off, agreeing a rescheduling or temporary halt, agreeing a reduced repayment, a third party taking over the obligation, or discharging it through bankruptcy, a voluntary arrangement or a debt relief order.
• Mixed debts. If advice covers several debts and some are due under a credit agreement, the advice on both types is likely to be debt counselling.

It also says debt counselling is not limited to overdue debts: it covers debts that are not overdue. Credit broking is a different permission from debt counselling, and debt adjusting is a third. Which you hold depends on what you do, and the website should describe only the activities in your permission. If you are unsure, read the Perimeter Guidance Manual and the FCA Register entry before you write a word.

The FCA's key-rules page for credit brokers summarises the requirements that touch web copy. It applies to both fee-charging and non-fee-charging brokers.

CONC 3.7.7R sets the broker statement rule: a firm that is a credit broker and not a lender must ensure any financial promotion states prominently that it is a credit broker and not a lender. CONC 3.7.8G adds that a statement is not prominent unless it is presented in such a way that the attention of the average person it is directed to is likely to be drawn to it. A line of small grey print in the footer will not meet that test. Place the statement near the top of the page, in a readable size, and repeat it on landing pages and in paid ads.

The FCA's 2022 letter lists phrases it identified in promotions: no credit check loans, loan guaranteed, pre-approved and no credit checks. Its concern is that consumers could be led to believe the lender will make no checks on credit status, even when a broker does not itself assess creditworthiness.

CONC 3.3.3R says a firm must not, in a financial promotion or a communication to a customer, state or imply that credit is available regardless of the customer's financial circumstances or status. Guidance in CONC 3.3.4G adds that a statement or implication that credit is guaranteed, pre-approved or free of credit checks may contravene that rule, and that a trading name, internet address or logo could fall within it. A domain name such as one promising guaranteed approval is therefore not outside the rules.

The same letter also flagged promotions for high-cost short-term credit that lacked the required risk warning: "Warning: Late repayment can cause you serious money problems. For help go to moneyhelper.org.uk". If your site promotes that kind of credit, the warning must be present as the rules require.

Safer alternatives

• Replace "guaranteed approval" with a factual statement of what the service does: "We introduce you to lenders; lenders decide whether to lend."
• Replace "no credit check" with an accurate description of the process, noting that lenders may carry out checks.
• Do not use urgency banners such as "approved in minutes" unless you can show it is true for typical customers.

Under the FCA's key-rules summary, all credit brokers are banned from charging fees to customers, and from requesting customers' payment details for that purpose, unless they comply with its requirements. They must give customers clear information about who they are dealing with, what fee will be payable, and when and how the fee will be payable, known as the information notice. They must also obtain the customer's confirmation that they are aware of the notice and its contents. The detail is in CONC 4.4.

The page adds that brokers must not take a fee from a customer's bank account without express authorisation, that the amount or likely amount should be disclosed as early as possible, and that a fee-charging broker must disclose its fee to the lender so that the lender can calculate the correct APR.

For a website build this translates into four design rules. Show the fee, or how it is calculated, before asking for card or bank details. Use a separate tick box to confirm the information notice, rather than burying it in terms. Do not pre-tick consent boxes. And repeat the refund position next to the payment button.

CONC 8 applies to firms with respect to debt counselling and debt adjusting. Its pre-contract rule, CONC 8.3.1R, requires a firm to provide sufficient information, in a durable medium, when the customer first enquires, so the customer can make a reasonable decision. The list covers, among other things:

• the nature of the service and the duration of the contract;
• the total cost, or the formula used to calculate fees, or an estimate of likely total cost;
• any arrangement, periodic, management or administrative fee, and any cancellation charge;
• how percentage or hourly fees are calculated and what the fees cover;
• when the customer may terminate and receive a refund;
• the effect on the customer's credit rating, including how long the matter will show and that future credit may be harder to obtain;
• whether a right to cancel applies;
• how payments will be allocated to lenders and when, including the date of the first payment;
• an explanation that compensation might be available if there is a shortfall in client money.

Other rules shape the site's content. CONC 8.3.2R requires advice to have regard to the customer's best interests, be appropriate to individual circumstances, and be based on a sufficiently full assessment. A sales funnel that pushes every visitor toward the same paid product does not fit that. CONC 8.4.3R forbids terms that say the customer has no refund entitlement in any circumstance or that the firm has no liability. CONC 8.7.2R limits fee structures so the customer does not pay all or substantially all of the fees in priority to making repayments to lenders under a debt management plan, and CONC 8.7.3G says allocating more than half of the sums received in any month to fees is likely to be viewed as undermining repayments.

Another rule worth building into the site concerns the UK's different debt solutions. CONC 8.2.2G, updated in 2026, says a firm should ensure it gives appropriate advice to customers living in different countries of the UK, and that failure to pay regard to differences in available debt solutions and enforcement procedures is likely to contravene Principle 2. If your site speaks only of English and Welsh options, say so, and signpost others.

Many visitors do not realise that free, impartial help exists. A fee-charging firm should not hide that fact. Under the FCA's rules on communications, a page that implies the visitor has no alternative, or that omits relevant information, risks being unclear or misleading. CONC 3.3.7G says that when communicating information a firm should consider whether omission of any relevant fact could make the communication misleading.

A fair approach is a short, visible panel on the home and service pages: what you charge, what a free service would typically provide, and where to find free help. It also builds trust with visitors who are comparing options.

Avoid claims you cannot substantiate. Writing off a percentage of debt, "stop creditor calls immediately" or "become debt-free in 12 months" are the kind of statements that need to be true for typical customers and supported by your own data. If a claim depends on the customer's circumstances, say what the circumstances are. Avoid naming the FCA in a way that suggests the regulator endorses you; CONC 3.3.6G says that if a promotion names the FCA as the regulator and refers to matters it does not regulate, it should make clear which matters are not regulated.

Before a debt advice or credit broking website goes live, check each item.

• Permission: your FCA Register entry covers each activity the pages describe.
• Legal name and status: on every page, with the broker, not lender statement prominent.
• Wording: no guaranteed, pre-approved or no credit check claims, including in the domain name, logo and metadata.
• Risk warning: present on any high-cost short-term credit promotion.
• Fees: full pre-contract information in a durable medium, and the information notice for broker fees.
• Debt solutions: UK-nation differences explained or signposted.
• Approval: who signed off the content, with the date, kept on file.
• Forms: only the data needed to start; payment details after fee disclosure.

Rules may move. In April 2026 the FCA published Consultation Paper CP26/15 on reviewing the CONC 3 financial promotions rules for consumer credit, with comments due by 17 June 2026. Check the FCA Handbook for the final position before relying on any detailed guidance paragraph quoted here.

If you need a site that is designed around these rules, with approval workflow, fee disclosure and form design, see our web design and GDPR-compliant website services, or send us a brief through the quote request page.

• FCA Handbook PERG 17: Consumer credit debt counselling
• FCA Handbook CONC 8: Debt advice
• FCA Handbook CONC 3: Financial promotions and communications
• FCA: Credit broking firms, key rules
• FCA Dear CEO letter, May 2022
• FCA CP26/15: CONC 3 financial promotions review