How Do You Market Debt Advice Online Without Breaking the Rules?

Marketing debt advice means working within the FCA’s rules for debt counsellors and debt adjusters, Google’s financial services verification and the ASA’s advertising codes. Write plainly, avoid promises, signpost free help and check where your leads come from.

This is general information, not legal advice. Compliance sign-off rests with the firm, so have a qualified adviser review your pages and ads before they go live.

Debt is one of the most tightly policed areas of search marketing, and for good reason: the people searching are often stressed. Content that works here is clear, calm and honest about alternatives.

We work on SEO for debt advice firms, and this guide quotes the FCA Handbook, Google’s policy pages and the ASA directly. Each rule number below was checked against its source on 3 October 2026.

Is Debt Advice a Regulated Activity?

Debt counselling and debt adjusting are FCA-regulated activities, and firms need the relevant permissions to carry them on. Whether a piece of content counts as debt counselling depends on whether it steers the reader.

What do the FCA definitions say?

The FCA’s page on limitations on debt permissions describes debt counselling and debt adjusting as activities carried on with a view to an individual entering into a particular debt solution. It points to PERG 2.7 for the full definitions and PERG 17 for what amounts to debt advice.

CONC 3.9 is titled for financial promotions and communications by debt counsellors and debt adjusters. If your page invites someone towards a debt solution on behalf of a regulated firm, treat it as that firm’s promotion, not a neutral blog post.

When does a blog post become debt counselling?

PERG 17.7 gives worked examples, all assuming the debts arise under a credit agreement or consumer hire agreement. A balanced, neutral explanation of how solutions work is likely not debt counselling, while advice that steers a debtor towards or away from a solution is.

Example in PERG 17.7	The FCA’s view	What it means for content
“I recommend you enter into a debt management plan”	Debt counselling	Don’t tell readers which solution to take
“I recommend you do not enter into a debt management plan”	Debt counselling	Steering away counts too
Explaining how different solutions work in a balanced, neutral way	Likely not debt counselling	Safe ground for guides
Comparing features and benefits of two solution types	Same as above	Comparison guides can work if balanced
Leaflets or illustrations to the general public	Not debt counselling	Public guides differ from one-to-one advice
Recommending one firm that offers only one solution	Could be debt counselling	Be careful with “best provider” pages

Where do lead generators sit?

PERG 17.7 says gathering personal information through websites promoted on search engines, then selling it on to debt advice providers, isn’t debt counselling in itself. It becomes debt counselling if the person recommends to the debtor how to deal with their consumer credit debt while communicating with them.

That is why lead capture copy needs as much care as the guide above it.

What Do the FCA’s Rules Require in a Debt Promotion?

CONC requires debt firms’ promotions to be clear, fair and not misleading, and CONC 3.9.3R adds a list of 16 items a promotion or communication must include. The list applies to the extent a previous communication to the same customer hasn’t already covered them.

What does clear, fair and not misleading mean here?

CONC 3.3.1R says each communication and financial promotion must be clearly identifiable as such, accurate and balanced, and presented in a way the average member of its audience is likely to understand. It must not disguise, omit, diminish or obscure important information, statements or warnings, and any comparison must be fair, balanced and meaningful.

CONC 3.9.2G confirms the rule applies to communications about debt counselling and debt adjusting.

What must a debt promotion include?

CONC 3.9.3R lists 16 items. The ones that most affect page design are below.

CONC 3.9.3R item	What it requires	Where it tends to go wrong
(1) to (4)	Services offered, relationships with business associates, fees and how they’re calculated, and whether any part comes from a third party or at extra cost	Fees buried in terms
(6) and (7)	Where true, that the service is profit-seeking and offered in return for payment	Styled as a public service
(8)	Unless you are a not-for-profit body, a reference to impartial information and not-for-profit sources of help	Missing or tucked away
(9)	Advantages, disadvantages and risks of each option explained, including the firm’s own	Only the benefits shown
(10) and (11)	The likely adverse effect on credit rating, and that IVAs, debt relief orders and protected trust deeds appear on a public register	Left out of “quick quote” pages
(12)	Where a solution is only available in one UK country, a statement saying so	UK-wide pages for Scottish products
(13)	A warning about arrears where payments to lenders aren’t made, with when distributions are made	Missing from payment plan pages
(14)	For IVAs and protected trust deeds, risks including bankruptcy if the arrangement fails	Treated as small print
(15)	That another option may be available and suitable	Single-solution funnels
(16)	That compensation might be available if client money held falls short	Omitted

Items (5) and (16) cover Financial Ombudsman Service eligibility and compensation. Read the full rule before you build a template.

What Can’t a Debt Promotion Say or Do?

It can’t claim a debt-free date, imply a free or impartial service when the firm is profit-seeking, guarantee outcomes with lenders or use search tactics to mislead people seeking free help. Several of these rules bite directly on SEO.

What do the guidance and rules ban?

CONC 3.3.10G lists practices likely to contravene the clear, fair and not misleading rule. They include using false testimonials, false or unsubstantiated claims about size, experience or pre-eminence, and, for debt solutions, claiming or implying that a customer will be free of debt in a specified time or that a solution is stress free or immediate.

It also covers online tools that recommend a debt solution without a sufficiently full assessment, emphasising savings from rescheduling without the downsides, and suggesting lower repayments without mentioning a longer term or higher total.

CONC 3.9.5R is a rule, not guidance, and says a promotion must not:

• Falsely claim or imply help is free, impartial or independent when the firm has a profit motive.
• Falsely claim or imply the firm is, or represents, a charity, not-for-profit body or government organisation.
• Promote a claims management service as a way of managing debts.
• Claim or imply the firm can guarantee a favourable outcome in negotiations with a lender.
• Unfairly direct a customer to a premium-rate number.

What does CONC 3.9.7R say about websites and search?

CONC 3.9.7R says a firm must not, unless it is a not-for-profit debt advice body or will provide such services, operate a look-alike website designed to attract customers seeking free, charitable, not-for-profit or governmental debt advice. It also says a firm must not use internet search tools or search engines to mislead a customer into visiting its website when the customer is seeking that kind of help.

For SEO, that rules out domains, titles and ad copy that imitate free services, and keyword choices designed to catch searches for free or government help under a misleading promise. It is the closest the Handbook gets to a rule about search tactics.

What does this look like in a title tag?

Risky copy (illustrative)	Rule it risks	Safer copy
“Write off your debt today”	CONC 3.3.10G(6); ASA enforcement notice	“Debt solutions explained: options, costs and risks”
“Free government debt help” on a paid service	CONC 3.9.5R(1), (2); 3.9.7R	“Debt advice from [firm], a paid service; free help is available”
“Be debt free in 60 months”	CONC 3.3.10G(6)	Describe the term, then the consequences
“Instant debt relief”	CONC 3.3.10G(6)	Describe the process and timeline plainly

How Do You Signpost Free Debt Advice?

CONC 8.2.4R requires a debt management firm to say prominently, in its first written or oral communication, that free debt help is available and that the customer can find out more through MoneyHelper, and to carry a MoneyHelper link on its website. Hiding it defeats the point.

What does the rule say?

CONC 8.2.4R says a debt management firm must prominently include, in its first written or oral communication, a statement that free debt counselling, debt adjusting and credit information services are available to customers and that the customer can find out more by contacting MoneyHelper. It must also include on its website a link to MoneyHelper’s debt advice locator, giving the full URL in the rule text.

CONC 3.9.4G adds that referring to impartial information should include making customers aware of publications from the Insolvency Service, the Department of Enterprise, Trade and Investment in Northern Ireland or debt advice published by the Scottish Government.

Where should the signpost go on the page?

Put it where a visitor will see it before any form, in the same body text size as the surrounding copy. A collapsed accordion or a footer link is hard to square with “prominently”.

If you build pages for a debt firm, treat the signpost as a template element that can’t be removed by a content editor.

What Are Google’s Rules for Debt Services Ads?

Google Ads lists the United Kingdom as allowed with limitations for debt services, and requires financial services verification before any financial services ad is shown to UK users. The organic results aren’t covered by Google Ads policy, but the FCA rules apply to them.

What does Google’s debt policy say?

Google’s debt services policy applies to advertisers who offer debt services directly, lead generators and those who connect consumers with third-party debt services. It permits ads for debt settlement and debt management services only where the location is approved, the ads comply with local laws and industry standards and the account has applied to advertise debt services.

For the UK it says “allowed with limitations” and refers to the financial services verification policy. Google adds that a policy violation won’t lead to immediate suspension without prior warning, and that a warning will be issued at least seven days before any suspension.

What does UK verification involve?

Google’s UK verification page says advertisers need to be verified to show financial services ads of any kind in the UK, including to UK users who appear to be seeking financial services. It covers services regulated by the FCA and those that aren’t.

Advertisers must show they are authorised by the FCA or qualify for an exemption. Google’s page lists the details needed, including the account customer ID, business details, domains, FCA registration number and a warranty on complying with financial promotion obligations.

Approved third parties, such as affiliates, resellers and lead generation agencies, need an FCA-authorised firm to initiate verification for them by submitting their domains. That firm can only vouch for third parties whose promotions it approves.

Does this change how you plan SEO and paid search?

Treat paid search as a separate workstream with its own verification, approval trail and landing pages, and keep organic pages to the same standard.

If you are weighing the channels, SEO or PPC compares the trade-offs, and our paid search work covers the ad side.

What Do the ASA and CAP Say About Debt Ads?

The CAP Code’s financial products section says debt management companies must comply with the FCA’s CONC 3 rules, and the ASA has published specific enforcement expectations for IVA and protected trust deed ads. Those rules apply to ads and to your own website’s marketing.

What did the CAP enforcement notice say?

In an enforcement update published on 23 June 2022, the ASA said ads for individual voluntary arrangements and protected trust deeds placed by insolvency practitioners and lead generators must clearly state the risks and fees. Lead generators must include a clear and prominent statement that they are a lead generation company which passes customer leads to third parties.

It said ads must not imply association with or approval from government, debt charities or regulated advisory bodies. They must not claim customers “can write off up to 85% of their debts”, or similar, without strong documentary evidence, nor exaggerate the simplicity or speed of the process.

What has the ASA said since?

In January 2025 the ASA published debt relief marketing tips. They cover ads that link gambling to debt relief, which are problematic, fabricated endorsements from organisations or well-known individuals, and ads that hide their commercial intent as a lead generation service.

The ASA also said debt relief ads shouldn’t be presented as simple or guaranteed, and that percentage claims about customers who benefit need evidence you can produce if asked.

Planning a regulated paid or organic campaign for a debt brand? Talk to us about SEO for debt firms.

What About Lead Generators and Debt Packagers?

Authorised firms must take reasonable steps to check lead generators under CONC 8.9, and debt packagers can’t receive referral fees from debt solution providers under CONC 8.3.11R. The referral fee ban started on 2 June 2023 for new firms and ended its implementation period on 2 October 2023 for existing ones.

What does the debt packager ban say?

The FCA’s Policy Statement PS23/5 was published on 2 June 2023. New debt packager firms were covered by the ban from that date, and existing ones and their appointed representatives had an implementation period to 2 October 2023, the FCA said on that date.

CONC 8.3.11R says a firm must not receive commission, fee or any other financial consideration, directly or indirectly, from a debt solution provider in connection with referring customers or related services. The FCA says the ban covers all debt solutions, not only IVAs and protected trust deeds, except payments excluded by CONC 8.3.14R.

What must firms check about lead generators?

CONC 8.9.2R, which carried a 31 July 2026 date when we read it, requires a firm to take reasonable steps before accepting sales leads from a lead generator. It must check that the lead generator’s advice, website content, advertising and commercial practices comply with applicable legal requirements, including the Digital Markets, Competition and Consumers Act, that the lead generator is registered with the Information Commissioner’s Office and that it has processes to comply with the Privacy and Electronic Communications Regulations.

CONC 8.9.4R sets out what the firm must take reasonable steps to make sure of afterwards. That includes the lead generator not carrying on debt counselling without permission, not claiming to provide it, making the true nature of its services clear and disclosing any financial interest in passing on the lead.

It also covers saying that the customer’s personal data will be passed on, not falsely claiming charitable or government status and having valid consent for electronic communications and automated calls.

Party	What the FCA material says	Marketing consequence
Authorised debt firm	Must take reasonable steps on lead generators (CONC 8.9)	Audit lead sources and the pages they use
Debt packager	Can’t receive referral fees from debt solution providers (CONC 8.3.11R)	Don’t build referral-fee funnels
Lead generator	The FCA reminds lead generators to consider PERG 17.7 and apply for authorisation where appropriate	Take legal advice on authorisation and show what you are

How Should You Write for Vulnerable Customers?

Assume the reader is under strain, and write so that someone with poor health, low resilience or limited literacy can still understand and act. The FCA’s FG21/1 guidance and CONC 8.2.7R set that expectation.

What does the FCA expect?

The FCA’s FG21/1 page defines a vulnerable customer as someone who, due to personal circumstances, is especially susceptible to harm, particularly when a firm isn’t acting with appropriate levels of care. It lists drivers such as poor health, life events, low resilience and low capability.

It also says firms should make sure communications are understandable for their target market and, where possible, offer more than one channel. The FCA added a note in July 2026 that FG21/1 refers to older publications that pre-date the Consumer Duty, and points firms to its Consumer Duty pages for current expectations.

What do the debt-specific rules add?

CONC 8.2.7R says a debt firm must establish and implement clear and effective policies and procedures to identify particularly vulnerable customers and deal with them appropriately. CONC 8.2.8G adds that most customers seeking debt advice may be regarded as vulnerable to some degree because of their financial circumstances.

For content, that means short sentences, no pressure language, no countdown timers and a visible route to free help. What is E-E-A-T is a useful companion, because trust signals matter more here than almost anywhere.

What Should a Debt Landing Page Contain?

A compliant debt page explains the options, states who you are and how you’re paid, and points to free help before it asks for personal details. Treat the page as a conversation with someone who may be frightened.

What to include

• Your firm name, regulatory status and how to check it on the FCA Register.
• A plain statement of fees, or how they’re calculated, using the content CONC 3.9.3R requires.
• The free debt advice signpost and MoneyHelper link required by CONC 8.2.4R.
• The consequences of each option, not only the benefits.
• Where an option is only available in one UK country, a statement saying so.

What to leave out

• Promises of a debt-free date or an “instant” fix.
• Claims to be free, impartial or independent if the firm earns a profit.
• Pressure devices such as false urgency; CAP rule 3.30 prohibits falsely stating that an offer is available only for a limited time.
• Unsupported claims about how much debt will be written off.
• Domains, titles or ads that imitate free or government services.

Your SEO titles and ads count here too. A headline such as “Write off your debt today” makes the kind of claim the guidance cautions against, however well it might convert.

How Do the Rules Differ Between the UK Nations?

The solutions on offer differ by nation, so your pages should describe the right options for the reader’s location. CONC 8.2.2G says failing to pay proper regard to those differences is likely to contravene Principle 2.

What are the main differences?

GOV.UK lists options such as debt management plans, administration orders, IVAs, debt relief orders and the Breathing Space scheme, and says that in Scotland you can arrange a Debt Payment Programme from the Debt Arrangement Scheme. The Scottish Government’s site describes a trust deed as a legally binding agreement to pay all or some of what you owe, with payments usually made for four years.

CONC 3.9.3R(12) also requires a statement where a solution is only available in a particular country of the UK.

How should you structure pages by nation?

If you target a UK-wide audience, don’t present an English solution as the only option to a Scottish reader. Separate pages by nation where the products differ, and link them clearly.

What is a topical map explains how to group them.

Have the legal detail checked by someone who knows each system, and treat our SEO and content marketing plans as secondary to that review.

How Do You Build a Compliance Loop for Debt Content?

Run every page, ad and lead source through the same cycle: draft in plain words, check against CONC and the advertising codes, approve with a named sign-off, then monitor and review. The cycle in the diagram above is the process we’d put in a brief.

What goes in the check?

Check each page against the CONC 3.9.3R list, the CONC 3.3.10G examples, CONC 3.9.5R and 3.9.7R, the signpost under CONC 8.2.4R, the Google verification status for any paid use and the CAP rules on evidence. Keep a dated record of who approved what.

Related: What Do FCA Financial Promotion Rules Mean for Insurance SEO Content?

What goes in the review?

Re-check pages, ads and lead sources on a schedule, and again whenever a rule changes. Compliant debt marketing is not about avoiding clicks; it’s about being accurate, signposting free help, avoiding promises and knowing where your leads come from.