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Cold email compliance for UK financial services: PECR, UK GDPR and FCA financial promotions

The three sets of rules that apply to every B2B cold email a lender, broker, collections firm or fintech sends, and a checklist Rept uses on its own campaigns.

By Finley Jopson, founder of Rept · Published 11 September 2026

Not legal advice. This guide summarises the rules as Rept applies them in its own campaigns. Check the current ICO and FCA guidance and take advice from your compliance officer or solicitor before relying on it.

Three sets of rules apply

B2B cold email in UK financial services sits under three regimes at once: PECR (the Privacy and Electronic Communications Regulations 2003) governs the sending of marketing email; UK GDPR and the Data Protection Act 2018 govern the personal data you process to send it; and the FCA financial promotions regime (section 21 of the Financial Services and Markets Act 2000 and the FCA Handbook) governs what you may say if the message invites or induces someone to engage in investment activity or consumer credit. Most compliance failures come from applying only one of the three.

1. PECR: who you may email

2. UK GDPR: the data behind the email

3. FCA financial promotions: what you may say

A campaign checklist

How Rept applies this

Every Rept campaign is built to these rules: corporate-subscriber targeting with legal-form checks, dedicated sender domains, a valid opt-out and privacy line on every email, suppression lists honoured across campaigns, human review of AI-written copy, and a standing rule that Rept never makes product-level claims on a client's behalf. The FAQ answers the common compliance questions in less detail; this guide is the long version.

Common questions

Is B2B cold email legal in the UK?

Yes, to corporate subscribers (limited companies, LLPs, Scottish partnerships, public bodies) provided the sender is identified and a valid opt-out is given, under PECR regulation 23. Sole traders and ordinary partnerships are individual subscribers and need prior consent under regulation 22. UK GDPR still applies to the personal data used.

Do I need consent to email a business contact?

Not for corporate subscribers. The usual lawful basis under UK GDPR is legitimate interests, documented in a legitimate interests assessment, with transparency information provided and the right to object honoured. Consent is required for sole traders and non-LLP partnerships.

When does a cold email become a financial promotion?

When its content invites or induces the recipient to engage in investment activity or enter a regulated credit agreement, for example by quoting rates or terms or prompting an application. A message that introduces a firm and invites a conversation is generally not one, but the judgement belongs to the client's compliance function.

Can an agency send financial promotions for me?

Only if the promotion is communicated or approved by an FCA-authorised person or an exemption applies. Rept avoids the question by keeping product terms and application prompts out of cold email entirely and leaving them to the client's approved materials.

Read all the answers

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