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Compliance

How does Consumer Duty fair value apply to marketing?

Last reviewed 22 April 2026 · Reviewed by Jake McQuillan

Quick answer

How does Consumer Duty fair value apply to marketing?

Fair value means marketing must not disguise total cost, must be aligned to target market, and must deliver real outcomes - meaning "free" offers and opaque fees invite scrutiny.

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Implications

  • Show ongoing fees alongside initial fees
  • Avoid misleading "free advice" framing if its loss-leader for high ongoing charges
  • Demonstrate target-market alignment in promotion register
  • Quarterly outcome review of promotions

Do

Replace "free" with "no-obligation" and disclose subsequent fee structure.

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JM
Reviewed by
Jake McQuillan
Founder at Platinum Prospects
Last reviewed 22 April 2026

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