Voxly Vision
Does this apply to me?
COBS 4 applies to firms promoting investments, including:
- Investment and trading platforms
- Fund managers and advisers
- Section 21 approvers — authorised firms that sign off others' promotions
It is enforced by the FCA, which has increasingly focused on the firms that approve promotions on behalf of unauthorised businesses.
Key rules
The core requirements:
- Fair, clear and not misleading promotions.
- Balanced risk warnings — risk given equal prominence to reward.
- Limits on mass-marketing high-risk investments to retail investors.
- Diligence by approvers — firms signing off promotions must do so properly.
Common breaches
Typical failings:
- Unsupported claims signed off by approvers.
- Professional-only promotions reaching retail investors.
- Over-reliance on third-party templates without proper checks.
- Risk warnings that are weak or buried.
How Voxly Vision checks an ad against this code
Every report shows an overall verdict, the rules at stake and a recommended fix. For investment promotions, Voxly Vision flags unbalanced risk warnings and claims that can't be backed up.
Recent rulings
FCA review of promotion approvers
Findings · 27 May 2026
Some firms approving promotions for others signed off unsupported claims, let professional-only promotions reach retail investors and leaned on third-party templates.
Rules: COBS 4 Fair, clear and not misleading, s.21 approvers
Frequently asked questions
What does COBS 4 require?
That investment promotions are fair, clear and not misleading, with balanced risk warnings and limits on mass-marketing high-risk products.
What is a section 21 approver?
An FCA-authorised firm that approves financial promotions on behalf of unauthorised businesses — a role under growing scrutiny.
Can high-risk investments be mass-marketed?
There are restrictions on marketing high-risk investments to retail investors.
Who enforces COBS 4?
The FCA.