Procedure for UK Financial Services Advertisers to meet Google’s Verification Requirements

This articles looks at the procedure and process for UK financial services advertisers to meet Google’s verification requirements for financial services advertising. Financial services advertisers in the UK must meet Google verification requirements by August 2021.

Globally, Google has introduced advertiser identity verification. This requires the advertiser to provide personal, business and regulatory information, including details of their financial license to provide regulated financial services.

In the UK, this follows from February 2021 when Google wrote to the Financial Authority, outlining its plan to tackle scam ads for financial services. In this letter, Google confirmed an update to its Financial Service policy, requiring financial services advertisers to complete its business operations verification. Furthermore, Google confirmed that it planned on implementing a procedure to verify the identity of financial services advertisers, a process it called the Advertiser Identity Verification. It stated that this process would require such advertisers to submit personal legal identification, business incorporation documents or other information to prove the identity of such advertisers.

From August 2021, if your company wishes to show financial services adverts of any kind in the UK, including adverts to UK users who wish to seek financial services, you, the advertiser, must be verified by Google. As part of the verification procedure, you will be required to demonstrate that you are authorized and regulated with the UK’s financial regulator, namely the Financial Conduct Authority, or the FCA for short. Alternatively, you must qualify for one of the exemptions list below. This requirement covers financial services whether or not they are regulated services by the UK’s regulator - the Financial Conduct Authority.

Key definitions

FCA-authorized advertisers: this means financial services advertisers that are authorized by the UK’s Financial Conduct Authority (FCA) to provide financial services activities.

Approved third parties: these are advertisers whose ads are approved by an FCA-authorized firm. Examples would be agents or appointed representatives working under a principle firm.

Exempt non-financial service advertisers: these are advertisers that do not promote financial services but have a strong reason to target users on Google who appear to be seeking financial services. Examples of exempt non-financial service providers are search engines and e-commerce platforms.

Google’s Verification Requirements for FCA-authorized Firms:

To be eligible for the UK FCA verification, financial services advertisers promoting regulated financial services activities must be authorized by the UK’s financial services regulator, namely, the Financial Conduct Authority (FCA) and complete Google’s identity verification program.

Step 1: UK FCA Authorization

For the verification process, you will need to provide the following information to Google using its form:

- Google Ads account Customer ID

- Name of the Authorized Representative applying for verification

- Your business details (full name, address, email address)

- Your domain(s) or website(s) included in the UK Financial Conduct Authority register and any of your other domain(s) or website(s) used for advertising on Google Ads which are not included in the FCA’s register

- UK FCA registration number (FRN) for your regulated company

- Warranty that you will comply with any and all obligations that relate to the communication of, approval of, and restrictions on, financial promotions as per applicable regulatory and legal requirements.

It is important that the information you provide during the verification process matches exactly with the business details found on the FCA’s register of authorized firms. This includes, your FCA registration or authorisation number, name of your firm, contact details and your registration number.

Once you have successfully completed Google’s verification, a certificate will be applied to your Google Ads account. Google will notify you on the status and outcome of your verification application.

Step 2: Advertiser Identity verification

Step 2 of Google’s verification process is applicable to advertisers who have not completed Google’s advertiser identity verification process before.

You will be asked to submit identity verification documentation in addition to providing the UK FCA authorisation for your business. You will receive an email and an in-account notification that will guide you through the identity verification process in Google Ads. After Google has sent you the email, you will have 30 days to start the identity verification process. If you fail to do so within this time, your account will be paused.

You must ensure that the information you provide for the identity verification process matches with the business details you submitted in Step 1.

In order to complete the advertiser identity verification process, your application must be submitted by an Authorized Representative. The Authorized representative may be required to submit a form of personal ID. You can see the list of acceptable identity documents here.

After completing steps 1 and 2, you will be permitted to display financial services adverts in the UK, to UK users.