last Updated 5 July 2021

Google Ads Policy Changes for Mortgage Brokers and Financial Advisers

Last week lots of the mortgage brokers in my group coaching programme started receiving emails from Google announcing an advertising policy update that is going to come into force later this year.

Dear Advertiser,  Google will be updating the Google Ads Financial Products and Services policy in August, 2021, to introduce new verification requirements for Financial Services advertisers targeting the UK. We will publish the policy update on August 30, 2021, and enforcement will take effect seven days later. Advertisers that have not successfully completed the updated verification process by the time enforcement begins will no longer be allowed to show financial services ads of any kind in the UK, including showing ads to UK users who appear to be seeking financial services. You can learn more about the new UK Financial Services verification requirements and initiate verification here.

The change affects an existing policy called the Google Ads Financial Products and Services policy. The updated version of the policy will be published in full on 30 August 2021. Here in the UK that’s a bank holiday so you’ll have plenty of time to read it in detail on the day it comes out if that kind of thing floats your boat!

In the meantime, Google has summarised what the policy updates will mean to people who run ads for financial services and products on Google Ads.

To save you ploughing through all the detail, here’s what you need to know about the new Google Ads Financial Products and Services policy if you’re someone who works in financial services in the UK.

If you're a mortgage broker or financial adviser who uses Google Ads you need to complete the verification process by 6 September 2021, otherwise your ads will stop running

What’s changing?

Once the new policy comes into force on 6 September 2021, advertisers of financial products and services in the UK will need to show that they are authorised by the Financial Conduct Authority (FCA) or prove that they qualify for one of the exemptions listed here.

Will mortgage brokers and financial advisers still be able to use Google Ads?

Yes, you will but you’ll need to complete the verification process and show that you are authorised by the FCA to carry out regulated activities. This is quite straightforward. Just complete this form and make sure you include the firm reference number (FRN) that you’re associated with on the FCA register.

What if I’m an introducer?

Some people promote mortgages and financial advice on Google Ads in the capacity of being an introducer. In other words, they are not FCA authorised individuals themselves but they pass enquiries onto people or firms who are authorised to give advice. Google calls these introducers Approved Third Parties and has created an exemption for them.

Once the new rules take effect, introducers will need to get the firm to which they introduce business to initiate the verification process for them. The authorised firm can do this using the same form as above, provided that:

  1. they have already completed the verification process themselves, and
  2. they have approved all the financial promotions (ads, landing pages, etc) used by the introducer. 

After this is done, the introducer will also need to complete the advertiser identity verification and business operations verification forms if they have not already done so.

All of the above could take a bit of time, especially if the firm you’re an introducer for has lots of other introducers who all need to go through this process. Therefore, if you are a financial services introducer who uses Google Ads, my advice would be to talk to your authorised firm now and get the ball rolling.

What about lead generation companies?

A lot of lead generation companies who provide mortgage leads and financial advice leads to brokers and IFAs are already authorised and regulated by the FCA. So they can get verified by providing their FRN in the same way as an advising firm would do.

But not all lead generation companies and other businesses that use their own websites to generate leads which they then sell to financial advisers and mortgage brokers are authorised by the FCA.

One solution is to apply for FCA authorisation – but that’s not a quick process and it’s not something that will fit every lead generation company’s business model.

So another option is to do what I did when I had my own mortgage lead generation company back in the day. Instead of becoming FCA authorised we found a tame mortgage broker who was directly authorised and arranged for him to check and approve all the websites and ads that we used for generating leads. That way, we got to put the all-important section 20 notice on our websites and the mortgage broker got some free leads each month (with the rest going to the other mortgage advisers who were paying to buy leads from us). So everyone was a winner!

I’m not a compliance expert, so don’t take this as legal or compliance advice, but I see no reason why a lead generation company couldn’t do something similar today and then they could get the firm that’s approved their website and ads to initiate the verification process for them in the same way that’s described above for introducers.

Again, if you’re going to go down this route then I’d suggest getting started as soon as possible so as you can make sure everything is sorted out before Google’s deadline of 6 September 2021.

Why is Google making these policy changes for financial services?

It seems the main reason that Google is tightening the rules is as a result of pressure to reduce the ease with which financial services scams can be advertised online. This pressure includes warnings from the FCA that it might take legal action if Google continued to accept financial ads from unregulated companies and individuals.

Previously, the FCA had tried to tackle the problem by running their own anti-scam ads in an effort to push the dodgy advertisers off the top spots. Great news for Google, who were getting rich from a bidding war between the poacher and the game-keeper, but probably not a great use of taxpayer’s money…

Is this good or bad news for financial advisers and mortgage brokers?

I don’t see any downside to this change if you’re a bona fide mortgage broker or financial adviser. The verification process looks pretty simple and anything which helps remove or limit the ability of unscrupulous people to promote financial scams has surely got to be good for the industry as a whole.

Admittedly it creates a bit of work for introducers and the firms that they work with, but at least Google has recognised the role that introducers play in the financial services industry and has created a mechanism whereby they can continue to advertise on Google.


Have you got a question or opinion about these upcoming Google Ads changes? Let me know in the comments.

About the author 

David Miles

As a digital marketing consultant, author and trainer, I specialise in helping businesses in the financial services sector use the internet to get more enquiries and increase profits.

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  • I think that it should be tighter. If you are advertising for financial services you should be FCA regulated because as an individual regulated with FCA you have so many advertising hoops to jump through that non-FCA regulated advertisers do not. For example quoting a rate, not having the appropriate customer-facing disclosures, etc. Hell half of the regulated advisors that advertise get it wrong, you can imagine what non-authorizised advertisers do to get the lead in the front door. Certainly non-transparent.

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