Advertising patient finance and 0% offers: the FCA rules
Last reviewed against the regulators’ own text, linked in the sources below.
This is general information, not legal advice.
On this page
Dental finance advertising is regulated by the Financial Conduct Authority (FCA) as soon as an ad invites patients to spread the cost with credit. The practice must be allowed to promote credit, the ad must be clear, fair and not misleading, and any ad that shows an interest rate or a cost-of-credit figure must include a representative example.12
The FCA's rules below cover finance promotions on treatment pages, ads, social posts and Google Business Profile posts. For the other rulebooks, see the rules that govern dental marketing. I do not recommend any lender or broker.
This is general information, not legal advice. Last reviewed: 1 October 2026.
When finance advertising is regulated
A financial promotion is a communication that invites or encourages someone to take out a financial product, here a credit agreement to pay for treatment. "Spread the cost of your implants" is one. So is a "0% finance available" badge; the FCA treats a reference to 0% credit as a rate of interest.2
The CAP Code, the advertising rulebook the ASA enforces, hands the technical rules for consumer credit ads to the FCA. It lists "other consumer loans" under the Consumer Credit Act among the areas the FCA regulates, while the CAP Code's general rules on truthfulness and social responsibility still apply to the whole ad.5 So the FCA decides whether your credit wording is right, and the ASA can still act on a misleading treatment claim in the same banner.
The FCA's core standard, CONC 3.3.1R, is that a financial promotion must be "clear, fair and not misleading". It must be clearly identifiable as a promotion, and must not emphasise benefits "without also giving a fair and prominent indication of any relevant risks".1 CONC is the FCA's Consumer Credit sourcebook; "R" after a number marks a binding rule and "G" marks guidance.
Two situations change the analysis:
- In-house instalment plans, where the patient repays the practice rather than a lender. The FCA says you need lending permission unless your lending is exempt, and gives repayment over more than 12 months as an example of lending that isn't exempt.3 Short, interest-free plans may be exempt; check the exact conditions with the FCA or an adviser before relying on that.
- Membership plans, which are not credit in the usual sense. They fall outside this page.
Who may promote finance
Section 21 of the Financial Services and Markets Act 2000 restricts who can communicate financial promotions. An unauthorised person can only do so if the promotion is approved by an authorised firm or an exemption applies. Since 7 February 2024, firms need specific FCA permission to approve promotions for others.6
For a dental practice that offers third-party finance, there are three realistic positions:
| Position | What it means | Who is responsible for the promotion |
|---|---|---|
| The practice holds its own FCA permission | The FCA says a practice that introduces patients to third-party lenders is likely to need Limited Permission for secondary credit broking3 | The practice |
| The practice is an appointed representative (AR) | An AR "carries on regulated activity under the responsibility of an authorised firm", the principal7 | The principal firm, which must make sure the AR complies |
| The practice is neither | It cannot lawfully communicate the promotion unless an authorised firm with approver permission approves it, or an exemption applies6 | The approving firm, for the approval |
Check which applies before anything goes live. The Financial Services Register on the FCA website shows whether your practice, or your principal, is authorised and for what.
What a finance ad must include
What an ad needs depends on what it says. The trigger for the full set of information is in CONC 3.5.3R: a promotion that "indicates a rate of interest or an amount relating to the cost of credit" must include a representative example and a postal address.2 A representative example is a worked example of a typical agreement, shown so patients can compare offers.
| If your ad... | It must also... | FCA rule |
|---|---|---|
| Is any finance promotion | Be clear, fair and not misleading; be identifiable as a promotion; name the firm communicating it | CONC 3.3.1R, 3.3.2R1 |
| Comes from a credit broker | State prominently that the firm "is a credit broker and that it is not a lender" | CONC 3.7.7R4 |
| Comes from a credit broker | Show the firm's legal name as on the Financial Services Register | CONC 3.7.5R4 |
| Comes from a credit broker | Indicate "the extent of its powers", for example whether it works with one lender or several | CONC 3.7.3R4 |
| Shows a rate of interest or a cost-of-credit amount | Include a representative example and a postal address | CONC 3.5.3R2 |
| Relates only to credit at 0% APR | The representative example is not required, but every other rule still applies | CONC 3.5.3R(2A)2 |
| Says "interest free" | Only if the total payable does not exceed the cash price | CONC 3.5.12R2 |
| Says "no deposit" | Only if no advance payment is required | CONC 3.5.12R2 |
A representative example under CONC 3.5.5R contains, where they apply: the rate of interest and whether it's fixed, other charges included in the total charge for credit, the total amount of credit, the representative APR (APR, the annual percentage rate, expresses the total cost of the credit as a yearly rate), the cash price and any advance payment, the duration, the total amount payable, and the amount of each repayment.2 The items must be shown together, clearly and with equal prominence, introduced by the words "representative example".
Monthly figures
Monthly figures are where most finance banners go wrong, because they are what practices most want to show.
The FCA's own guidance settles the main question. CONC 3.5.4G says an amount relating to the cost of credit includes "any repayment of credit (where it includes interest or other charges)". It also says a rate of interest includes a monthly rate and "reference to 0% credit".2 So:
- Interest-bearing plan, monthly figure shown: the repayment includes interest, so the representative example and postal address are required, even if no rate appears in the ad.
- 0% APR plan only: a monthly figure or "0%" doesn't need a representative example, because of CONC 3.5.3R(2A), but "interest free" must be literally true and every other rule applies.2
- Either way: the figure must not mislead. It has to relate to the treatment and price actually on offer, and must not hide the length of the agreement or the total payable.1
Illustrative figures, not benchmarks: a £3,000 treatment on a 0% APR plan over 12 months gives £250 a month and a total payable of £3,000. "From £250 a month" for that plan should sit next to "12 monthly payments, 0% APR, total £3,000". The same headline on a plan that charges interest needs the full representative example.
How finance fits into the structure of a price page for high-value treatment is covered in price and finance pages for full-arch treatment. This page stays on the rules.
Common breaches
These are the patterns that break the rules quoted above. I describe the defect, not any practice.
| Pattern | Why it breaches | Fix |
|---|---|---|
| "0% finance available" when some plans carry interest | Misleading by omission; "interest free" only when literally true | Say which plans are 0% and for what term |
| A rate or APR shown without a representative example | Triggers CONC 3.5.3R | Add the full representative example |
| APR shown without the word "representative" | CONC 3.5.9R requires the representative APR to carry that word8 | Label it "representative APR" |
| No broker statement | CONC 3.7.7R requires it | Add "[legal name] is a credit broker, not a lender" |
| Trading name only, no legal name | CONC 3.7.5R requires the Register name | Use the name as it appears on the Register |
| Promotion run by an unauthorised practice, unapproved | Section 21 restriction | Get permission, become an AR, or get approval |
| Benefits only, no mention of the commitment | Fails the balance test in CONC 3.3.1R | Show the term and total payable |
| Finance offer in a Google Business Profile post | Google's policy bars calls to action or offers for regulated services, including "financial services"9 | Keep finance offers on the website |
The last row is a platform rule, not an FCA rule, but it catches practices that paste the same finance promotion everywhere.
If you offer full-arch treatment, the next read is full-arch price and finance pages, which puts these rules into a page layout. For a free first read of your public finance wording, email [email protected].
Sources
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FCA Handbook, CONC 3.3.1R and 3.3.2R. https://www.handbook.fca.org.uk/handbook/CONC/3/3.html (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4
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FCA Handbook, CONC 3.5.3R, 3.5.5R and 3.5.12R. https://www.handbook.fca.org.uk/handbook/CONC/3/5.html (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12
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Financial Conduct Authority, "Vets and dentists", first published and last updated 15 November 2023. https://www.fca.org.uk/firms/authorisation/consumer-credit-brokers/vets-dentists (accessed 1 October 2026). ↩ ↩2 ↩3
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FCA Handbook, CONC 3.7.3R, 3.7.5R and 3.7.7R. https://www.handbook.fca.org.uk/handbook/CONC/3/7.html (accessed 1 October 2026). ↩ ↩2 ↩3 ↩4
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CAP Code, section 14 (Financial products), background. https://www.asa.org.uk/type/non_broadcast/code_section/14.html (accessed 1 October 2026). ↩
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Financial Conduct Authority, "Approving financial promotions". https://www.fca.org.uk/firms/financial-promotions-and-adverts/approving-financial-promotions (accessed 1 October 2026). ↩ ↩2
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Financial Conduct Authority, "Appointed representatives and principals", updated 26 November 2025. https://www.fca.org.uk/firms/appointed-representatives-principals (accessed 1 October 2026). ↩
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FCA Handbook, CONC 3.5.9R(3): "the representative APR must be accompanied by the word 'representative'". https://www.handbook.fca.org.uk/handbook/CONC/3/5.html (accessed 1 October 2026). ↩
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Google Business Profile Help, "Prohibited and restricted content", regulated goods and services. https://support.google.com/business/answer/7400114?hl=en-GB (accessed 1 October 2026). ↩