The overarching requirement that financial promotions must be “fair, clear and not misleading” remains unchanged. However, firms will have greater discretion in how they meet this standard, with less reliance on detailed CONC rules and more emphasis on their own judgement. In practice, compliance will increasingly be assessed by reference to whether communications deliver good consumer outcomes – particularly in terms of consumer understanding under PRIN 2A.5. This In Practice article reviews the key changes.
In this In Practice article, the authors consider the recent Court of Appeal decision in Revenue and Customs v Burlington Loan Management DAC [2026] EWCA Civ 461 and its implications for practitioners.