Rules and ethics
Edinburgh and Glasgow affiliate compliance under FCA and ASA rules
Edinburgh Glasgow affiliate compliance FCA ASA rules explained: named duties, publisher obligations, approval steps and record keeping for Scottish programmes.
What to take away
- Edinburgh Glasgow affiliate compliance FCA ASA work means treating a promoted link as a financial promotion when the firm is authorised.
- The FCA's financial promotion rules sit with the firm that approves the content, not with the publisher alone.
- The CAP Code applies to affiliate ads from Scottish finance firms, so every paid link needs a clear ad label.
- Named duties include fair, clear and not misleading claims, risk warnings, and a named approver for each promotion.
- Publishers must disclose commercial relationships and keep evidence of what was published and when.
How Scottish financial and professional services firms use affiliate promotions
Edinburgh and Glasgow host different halves of the Scottish finance economy. Edinburgh holds the head offices of abrdn, Baillie Gifford and Scottish Widows, plus NatWest Group's Gogarburn campus, so affiliate briefs there usually pass through an in-house compliance team.
Glasgow's financial employers lean towards banking operations and technology hubs such as Barclays at Buchanan Wharf and JPMorgan Chase at Argyle Street, and its publisher base is smaller and more agency-led.
Scottish programmes still settle payment per tracked click, lead or application, but the paperwork is local. An Edinburgh platform paying a Glasgow publisher for ISA transfer leads creates a promotion approved in one city and published in the other. That split is why approval notes need to name both parties and the version approved.
Scottish firms use affiliates for current account switching, mortgage introductions, investment platform sign-ups, insurance quotes and debt advice referrals. Each vertical carries its own approval burden. Debt advice and credit broking attract the heaviest scrutiny.
Affiliate marketing rules and ethics matter most when a programme scales past a handful of partners. A Scottish firm adding fifty publishers in a quarter needs the approval process to grow with it, not after it.
FCA rules applied to Edinburgh and Glasgow affiliate content
The FCA regulates financial promotions under rules in its Handbook, mainly COBS 4 for firms communicating with clients. A promotion must be fair, clear and not misleading. It must be balanced, so a headline rate is not shown without the conditions attached to it.
An affiliate post written by a Glasgow publisher and approved by an Edinburgh firm is the firm's promotion. The firm carries responsibility for the content, even when an external partner drafted it. That is why approval cannot be a formality.
Risk warnings are a named requirement. Investment promotions need a capital-at-risk warning. Credit promotions need representative APR figures where the rules demand them. Insurance promotions need the limits of cover stated plainly.
Affiliate marketing UK rules also bite on targeting. A promotion aimed at UK consumers from a Scottish firm falls inside the regime regardless of where the publisher is registered. Offshore hosting changes nothing.
Firms should check affiliate marketing advertising rules before briefing a campaign, because a compliant landing page does not rescue a non-compliant advert. The claim in the advert is what gets judged.
ASA and CAP Code duties for Scottish finance affiliates
The CAP Code applies to affiliate ads from Scottish finance firms, and it covers paid search copy, social posts, email and publisher articles. Its sections on substantiation, misleadingness, comparisons and recognition of marketing communications do most of the work here.
Recognition is the duty publishers feel most. A reader must know a link or recommendation is paid. Online Affiliate Marketing explains the disclosure expectations that follow from that.
Substantiation is the second duty. If a Glasgow publisher writes that a platform has the lowest fees, the claim needs evidence. "Best" and "cheapest" invite a challenge unless the comparison is defined and provable.
Comparisons must be like for like, with the basis stated. A table comparing account fees must compare the same account tier and the same date. Stale data is a common failure in Scottish affiliate content.
The rulings database provides enforcement examples for finance affiliates, and reading a handful of recent decisions is faster than guessing at the boundary. Rulings show how the regulator treats risk warnings placed below the fold or buried in a footnote.
Advice for businesses on advertising rules affecting Scottish finance promotions is free and worth using before a launch. Firms can ask about a specific concept before spend is committed.
Named compliance requirements and publisher duties
Six requirements do most of the work in a Scottish finance affiliate programme. Treat them as the minimum, not the ceiling.
- Identify the authorised firm and its FCA reference on any page that promotes a regulated product.
- Label paid content clearly, using wording a reader understands without effort.
- Substantiate every performance, price and comparison claim with dated evidence.
- Include the risk warning or APR statement the product type requires, in the same view as the claim.
- Record who approved the promotion and when approval was given.
- Keep the published version, so an archived page can be produced on request.
Publisher duties sit alongside those. A publisher must disclose the commercial relationship, avoid inventing personal experience, keep claims current, and stop promoting a product once the firm withdraws approval.
A worked example shows how this lands. An Edinburgh investment platform briefs a Glasgow personal finance blog. The blog drafts a piece on ISA transfers, with a table of charges and a link to open an account.
The firm's compliance team checks the table against its current fee schedule, adds a capital-at-risk warning above the table, and confirms the ad label reads as paid. The publisher keeps the signed brief, the approved draft and the live URL. When the fee schedule changes, the firm asks for the table to be updated and re-approved.
That is the whole cycle. The failure mode is a publisher editing copy after approval, or a firm forgetting to withdraw an old post when a product closes.
An affiliate marketing disclosure policy removes most of the ambiguity, because it tells publishers exactly what wording and placement the firm expects.
- Authorised firm name and FCA reference present on the page
- Paid link or advertorial label visible without scrolling
- Risk warning or APR statement beside the claim it qualifies
- Comparison basis and data date stated
- Named approver and approval date recorded
- Archived copy of the published version retained
- Review trigger set for fee or product changes
Approval and record-keeping workflows for Scottish programmes
A workable workflow has four stages: brief, draft, approve, monitor. Scottish firms with small compliance teams often run this in a shared tracker rather than a dedicated platform.
- Brief the publisher in writing, naming the product, the audience, the required warnings and the claims that are off limits.
- Review the draft against the CAP Code and the FCA's financial promotion rules, and return comments in one pass.
- Approve in writing, naming the approver and the version approved, then release the tracking link.
- Monitor live pages monthly, and re-approve after any fee, rate or product change.
Record keeping should survive staff turnover. Keep the brief, the approved draft, the approval note, the live URL and a dated screenshot. Under UK GDPR, personal data collected through affiliate forms needs a lawful basis and a retention period, and the ICO expects both to be documented.
Tax and reporting sit outside compliance but affect the same programme. Payments to individual Scottish publishers may fall within HMRC self-assessment, and VAT treatment depends on the service supplied. Firms should confirm the position with their adviser rather than assume.
Scale brings its own discipline. Check affiliate marketing rules and ethics before you scale, because a programme that grows from ten publishers to a hundred multiplies the approval workload rather than the risk appetite.
The test is local and practical. An Edinburgh platform whose fee table sits on a Glasgow publisher's page after the rates changed is a live risk, and so is a paid link labelled only in a site footer. Scottish firms should fix both before the next campaign.
Common questions
Does the FCA regulate affiliate publishers directly? Usually not. The authorised firm owns the promotion, so the FCA's financial promotion rules bind the firm. Publishers can still face action from other regulators for misleading claims.
Who approves an affiliate post about a regulated product? The authorised firm's compliance function, or a person named in its approval process. A publisher cannot self-approve a financial promotion.
Do Scottish affiliates need to label every link as paid? Yes, where the link is commercial. The label must be clear to an ordinary reader, not hidden in a footer or a hover state.
How long should approval records be kept? Long enough to evidence the promotion while it runs and afterwards. Many firms keep records for several years, aligned with their wider compliance retention schedule.
What happens if a publisher changes copy after approval? Approval lapses. The firm should treat the edited version as a new promotion, review it and re-approve before it stays live.