The new financial promotions gateway requires firms seeking to approve the financial promotions of unauthorised persons to obtain the FCA's permission during the upcoming application window, unless an exemption to the gateway applies. To apply, firms will be required to submit a variation of permission application to the FCA.
Not only will the application process be relatively time consuming and costly for authorised firms, but the application window is short. Existing authorised firms will be able to apply to the FCA for permission during the initial application period. That period will run from 6 November 2023 to 6 February 2024. If an authorised firm doesn’t apply during the 3 month window, the firm will need to stop approving financial promotions for unauthorised persons on 7 February 2024.
Recorded: Friday 3 November 2023
Speakers: Alex Ainley, Partner
Camilla Jessel, Managing Associate
The webinar covers:
- An overview of the new regime
- The application process (timing and costs)
- Exemptions available to UK authorised firms
- Ongoing obligations that will apply to UK authorised firms
- Concerns for fund managers that are looking to apply for fund approval under the OFR
Financial Promotions Gateway mini-Toolkit – how can we help you?
We have developed a mini-toolkit to help you with understanding the new Gateway and your obligations. The toolkit provides:
- Guidance on how to answer the VoP questions
- Library of useful documents
- Guidance on what “competence and expertise” looks like
- Governance documents, including the relevant board memo and resolutions
For more information please contact us.

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