What the FCA's latest findings mean for firms using AI in their marketing workflows

The FCA published its Consumer understanding: good practice and areas for improvement report in March 2026. For marketing and compliance leaders in regulated firms, the report is worth reading closely because it sets out, in specific practical terms, the FCA’s findings from a recent review of how firms are delivering the consumer understanding outcome.

For firms where AI or automation touches any part of the marketing and financial promotions process, the report also raises an additional question. Can your current workflows demonstrate what the FCA now describes as good practice?

For bethebrand clients, the answer is yes. Our platform has been built alongside UK financial services marketing and compliance teams for over 20 years. Approval trails, version histories, documented sign-off and content checks are not features firms need to retrofit. They are how the platform works by default.

What the FCA expects

The report describes good practice in practical terms. 

Firms performing well use evidence-based approval steps and maintain documented sign-off processes with clear records of how wording and decisions were agreed. They check for plain English and ensure risks and benefits are given equal prominence across all channels.

On monitoring, the FCA expects firms to act on evidence; identifying where promotions might confuse or mislead, rewriting wording where needed and retesting changes to confirm the impact.

On governance, the report highlights clear senior responsibility, structured oversight and a feedback loop that connects monitoring insight back into communication decisions.

The areas for improvement are equally instructive. Many firms approved promotions without monitoring outcomes. Accountability was often unclear. Records frequently failed to show what had changed, why it changed or what impact it had on customers. Several firms could not demonstrate a clear link between insight and action.

How bethebrand addresses this directly

bethebrand is built for exactly the compliance standard the FCA describes.

When a compliance team member needs to show what was approved, by whom and on what basis, the platform produces a full sign-off history instantly. Version history, named approvals, substantiation links and recorded responses to identified issues are generated within the workflow itself, not reconstructed afterwards.

Approval processes are structured and documented. Workflows route content to the right reviewers at the right stage. Our SeeDynamic platform enforces content checks against a set of clear rules consistently across all financial promotions (including things like mandatory disclosures, restricted terminology and readability) before content reaches formal compliance review. When an asset changes, the record reflects it.

For senior leaders carrying SM&CR accountability, that evidence is available without asking for it to be assembled. It exists because the workflow produces it.

The FCA’s good practice description reflects how bethebrand’s clients are already using the platform. 

Why AI raises the bar further

AI and automation increase content volume, variation and distribution speed.

That changes the governance and compliance context in ways that matter for each of the FCA’s findings.

Documented approval processes can become harder to maintain when content is generated or adapted at scale. A workflow designed around reviewing a single static asset does not transfer cleanly to an environment where multiple variations exist, some drafted or refined with AI assistance.

Monitoring effectiveness becomes more complex when the volume of live content grows and when the origin of specific wording is not always clear. If a firm cannot trace which version of a communication was approved, by whom and on what basis, producing that evidence under scrutiny becomes a manual exercise rather than a straightforward retrieval.

Governance and oversight depend on accountability being clearly owned. Where AI functionality is embedded in drafting tools, workflow platforms or third-party systems, firms need to demonstrate that human review and sign-off remain central.

The FCA flags that many firms already struggle to evidence that workflows support informed decisions:

“Across several firms, monitoring was described but there was no clear evidence of a process to feed this information back into governance or to use it to improve communications. This shows firms were checking information but not consistently acting on what they learned, which falls short of what is expected under the Duty. Firms must not only monitor but also act on what the monitoring reveals.”

In a higher-volume, AI-influenced environment, that gap widens. The governance bar does not move. The distance to clear it does.

A practical starting point

Our new report Governing AI in financial promotions sets out a fuller framework for how firms should structure AI governance across the financial promotions lifecycle, including the practical distinction between deterministic automation and generative AI and where each belongs within a controlled workflow. 

The accompanying board paper also provides a concise summary for senior leaders. 

The FCA is not asking firms to prove that AI is flawless. It is asking firms to demonstrate that governance, oversight and evidencing remain robust when AI is part of the process. That is a systems and workflow question as much as it is a compliance one.

Firms with structured marketing workflows, clear approval controls and embedded evidence are better placed to answer it. For those that have not yet reached that point, the FCA’s findings provide a clear indication of where to focus.