New Google Advertising Requirements for Financial Services

On August 30, the Google Ads Financial Products and Services Policy was updated to introduce new requirements for financial services advertisers targeting the UK. Advertisers now need to be verified by Google in order to show financial services ads of any kind in the UK. As part of the verification process, advertisers must demonstrate that they are authorized by the Financial Conduct Authority (FCA) or qualify for an exemption. This verification is required for all ad formats and extensions. Advertisers must have completed the updated verification process by enforcement on 6 September 2021 to show financial services ads to UK users.

To be eligible for this FCA verification, advertisers promoting regulated financial services activities must be authorized by the FCA and complete Google’s identity verification program. Once you have successfully completed Google’s verification, a certificate will be applied to your Google Ads account. Google will notify you of the status and outcome of your verification application.

Are there any exemptions?

If advertisers cannot demonstrate that they are authorized by the FCA, then they must demonstrate that they qualify for one of the exemptions to the process by meeting one of the following definitions:

  • An Approved Third Party, which google has defined as Advertisers whose ads are approved by an FCA-authorized firm. As an approved third party, you will need an FCA regulated firm to initiate the verification process for you by submitting a list of domains or websites that you use to promote their services. This may be the case for agents or appointed representatives working under a principal firm.
    • If you are already an FCA Authorised Firm you can start the verification process for an Approved Third-party using Google’s verification form. 
  • If you meet the definition for ‘Exempt non-financial services advertisers’, you can also apply for verification. Google has defined this term as ‘advertisers that do not promote financial services, but that have a compelling reason to target users who appear to be seeking financial services. In the initial announcement, Google uses the examples of eCommerce platforms or Search Engines relating to Financial Services.
  • Finally, most advertisers that meet the definition of an exempt government entity above will be verified automatically by Google. An Exempt Government entity has been defined as UK government institutions, regulators, or authorities operating with .gov.uk domains, intergovernmental organizations such as the United Nations, central banks of UK and Europe, the UK Advertising Standards Authority, or entities any one of these approves for this policy.

Google also said ads relating to categories including debt services, gambling, cryptocurrencies and credit repair, among some others, would not be considered financial services for the purposes of the new policy, but will still be required to comply with all other Google ads policies.

Why has Google put in place this verification?

Google’s decision to allow only FCA-regulated financial entities to run ads for financial products and services is a decision following the previous warnings from the FCA that it may take legal action if Google continued to accept and show financial ads without screening. Google and other Pay-Per-Click advertising services have come under recent pressure to take stronger action over scam advertisements, there has also been an increase in online fraud as a result of the pandemic which may have accelerated the process. According to Google, this update builds on the past 18 months of ‘significant work’ with the FCA to help tackle these issues. Ronan Harris, Vice President and MD, Google UK & Ireland said that the move to verify financial services companies is a measure to ‘help prevent scammers exploiting our platforms’. The company’s blog also claims that it has pledged $5 million in advertising credits to support financial fraud public awareness campaigns in the UK.

An FCA spokesperson has responded to Google’s new verification process, stating that, ‘We welcome all steps which protect consumers from scams and recognise that this is a positive move from Google.’ However, it was made clear that whilst this move from Google is positive, it is not a permanent solution and that the next step in battling online scammers ‘requires regulation’.

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