The Financial Markets Authority requires specific information on financial services websites, but most practice managers learn this from their lawyer rather than from a practical web implementation guide. The result is either over-compliance -- pages of dense legal text that nobody reads -- or under-compliance, where required disclosures are buried in PDFs that visitors never open. Neither serves the purpose the regulations intend.
The Financial Markets Authority regulates financial advice providers under the Financial Markets Conduct Act 2013 and the Financial Markets Conduct (Regulated Financial Advice Disclosure) Regulations 2020. For practice managers responsible for website compliance, the practical question is not what the legislation says in full -- it is what needs to appear on your website as a result.
The disclosure regulations require that certain information be provided to clients before financial advice is given. Your website is typically the first point of contact, which makes it the logical place for upfront disclosure. The FMA does not prescribe exact website layouts, but it does require that disclosure information be readily accessible -- not buried, not hidden behind logins, and not formatted in a way that discourages reading.
The key distinction that matters for web implementation: the regulations differentiate between information that must be disclosed proactively (before advice is given) and information that must be available on request. Your website needs to handle both categories, but they require different approaches. The proactive disclosures need prominent placement. The on-request items need to be obtainable -- but do not necessarily need their own webpage.
The disclosure requirements under the 2020 regulations apply to Financial Advice Providers (FAPs) -- entities licensed by the FMA to provide regulated financial advice. If your firm holds a FAP licence, your website must comply. If your firm is an accounting practice that does not provide regulated financial advice, the disclosure requirements described here do not apply, though other obligations under the Companies Office and the Tax Administration Act may impose their own website requirements.
The scope extends to anyone giving regulated financial advice on behalf of a FAP, including nominated representatives and financial advisers engaged by the provider. If your website lists individual advisers, each adviser's disclosure information must be accessible, either through individual profile pages or through a centralised disclosure document that covers all advisers.
Sole practitioners operating as their own FAP have the same obligations as large advisory firms. The FMA does not scale requirements by firm size. A one-person operation in Tauranga has identical website disclosure obligations to a fifty-adviser firm in Auckland. The implementation can be simpler -- one disclosure statement covering one person -- but it must still be present and accessible.
The FMA's guidance uses the term "readily accessible," which in web terms means reachable within one or two clicks from any page on your site. The standard implementation is a dedicated disclosure page linked from your main navigation or footer navigation -- both are acceptable, but main navigation is stronger from a compliance perspective because it signals prominence.
The disclosure statement page should be a standalone page, not a PDF download. While PDF disclosure statements are common and technically compliant, they create friction -- particularly on mobile devices where PDF viewing is inconsistent. A well-formatted HTML page loads faster, reads better on all devices, and is indexable by search engines, which matters if a potential client searches for your firm name plus "disclosure."
If your firm has multiple advisers, you have two implementation options. A single disclosure page covering all advisers with clearly separated sections, or individual disclosure pages linked from each adviser's profile. The latter is cleaner for firms with more than three advisers. Either way, the content must cover the matters specified in the regulations, including the nature and scope of advice, fees, conflicts of interest, and complaints process.
The Financial Markets Conduct (Regulated Financial Advice Disclosure) Regulations 2020 specify the information that must be included. For web implementation purposes, the mandatory disclosure content includes: the name and contact details of the FAP, the types of financial advice provided, any limitations on the scope of advice, the fees and costs of the advice (or how they are calculated), any conflicts of interest or commissions, the complaints handling process, and information about the dispute resolution scheme the FAP belongs to.
Each of these items requires thoughtful web presentation. Fees, for example, should not be described in legal boilerplate that obscures the actual cost to the client. "Fees are charged in accordance with our fee schedule" tells the visitor nothing. "We charge a flat fee of $X for an initial financial plan" or "Our ongoing advice fees are calculated as a percentage of funds under advice, typically between X% and Y%" -- these meet the disclosure requirement and serve the visitor.
Conflicts of interest disclosures deserve particular attention. If your advisers receive commissions from product providers, this must be disclosed clearly. The FMA has been explicit that generic statements about "potential" conflicts are insufficient -- the disclosure must describe the actual conflicts that exist in your business model.
A technically complete disclosure statement presented as a wall of 10-point legal text is compliant in letter but problematic in practice. If the FMA ever queries whether a client was adequately informed, a disclosure statement that was clearly designed to discourage reading is a weaker defence than one formatted for genuine comprehension.
Use clear headings that match the regulatory categories: "What We Do," "What It Costs," "Conflicts of Interest," "How to Complain." Use plain language -- the FMA explicitly encourages this. Break content into short paragraphs with adequate spacing. Use bullet points for lists of services or fee structures. The goal is a document that a reasonably informed adult can read and understand within five minutes.
Consider the mobile experience specifically. Your disclosure page will be read on phones. Test the page on a mobile device and confirm that the text is readable without zooming, that headings provide clear navigation, and that contact details and links are tappable. A disclosure statement that is technically present but practically unreadable on the device most visitors use is a vulnerability you can eliminate with basic responsive formatting.
Every FAP must belong to an approved dispute resolution scheme -- either the Financial Services Complaints Limited (FSCL) or the Insurance and Financial Services Ombudsman Scheme (IFSO). Your website must disclose which scheme you belong to and how a client can make a complaint, both to your firm directly and to the dispute resolution scheme.
The complaints page should describe your internal complaints process in practical terms: who to contact, how (email, phone, letter), what information to include, and what timeline to expect for acknowledgement and resolution. Generic statements like "we take complaints seriously" are filler -- the visitor needs to know the specific steps they would follow to raise a concern.
Include direct links to your dispute resolution scheme's website. FSCL and IFSO both have online complaint forms, and linking to them demonstrates transparency. The FMA views ease of access to the complaints process as a marker of good conduct -- making it difficult to find or understand is a conduct risk. Your complaints page should be linked from your footer navigation at minimum, and ideally from your disclosure statement as well.
Practice managers sometimes resist creating a prominent complaints page because they worry it signals that complaints are expected. The opposite is true. A clear, accessible complaints process signals professional maturity and regulatory compliance. Visitors who see a well-structured complaints page think "this firm operates properly" -- not "this firm must have a lot of complaints."
The framing matters. Lead with your commitment to service quality, then describe what happens if something falls short. "We are committed to providing advice that meets your needs. If you are not satisfied with any aspect of our service, we want to hear about it" -- this frames the complaints process as part of your service commitment, not as an admission of likely failure.
Avoid legalistic language on the complaints page. The regulations do not require your complaints disclosure to read like a legal document. Write it in the same professional but accessible tone as the rest of your website. The person reading your complaints page may be frustrated or anxious -- dense legal prose will compound those feelings rather than resolve them.
The regulations distinguish between information that must be disclosed proactively -- before or at the time advice is given -- and information that must be available on request. For website purposes, proactive disclosure items should have their own dedicated pages or clearly marked sections within a disclosure page.
Proactive items include: the name of the FAP and its licence details, the nature and scope of financial advice offered, fees and expenses (or how they are determined), material conflicts of interest and commissions, and the complaints and dispute resolution process. These items form the core of your disclosure page and should be accessible without the visitor needing to ask for them.
The practical test is: if a visitor finds your website, reads your disclosure page, and then contacts you for advice, have they been given the information the regulations require before advice is provided? If yes, your proactive disclosure is adequate. If your disclosure page omits any of the required items and relies on providing them later in the advice process, there is a gap between your web presence and your regulatory obligations.
Certain information must be available on request but does not need to appear on your website proactively. This includes detailed fee schedules for specific services, the full text of your internal complaints procedure (as opposed to the summary on your website), and information about specific products you may recommend. The on-request category is smaller than most firms assume -- the 2020 regulations shifted many items into the proactive category.
For on-request items, your website should make clear that these are available and how to obtain them. A statement on your disclosure page such as "Detailed fee schedules for specific services are available on request -- contact us at [email/phone] for a copy" meets the requirement. The visitor knows the information exists, knows how to get it, and can request it before engaging your services.
Do not use the on-request category as a way to avoid disclosing uncomfortable information on your website. The FMA monitors for this. If your fee structure is complex and you list it as "available on request" to avoid publishing numbers on your site, that is technically compliant but practically questionable. The FMA's clear preference, expressed in multiple guidance documents, is for maximum transparency. Meeting the minimum is lawful but not risk-free.
Uploading a PDF disclosure statement and linking to it from your footer is the path of least resistance, and roughly 60% of NZ FAP websites take this approach. It is technically compliant but creates three practical problems that a dedicated webpage avoids.
First, PDFs are poorly indexed by search engines. A potential client searching for "[Your Firm Name] disclosure statement" may not find the PDF, even though it exists on your site. An HTML page with the same content ranks naturally. Second, PDFs render inconsistently on mobile devices. Some phones open them in a browser viewer, some trigger a download, and some display them at desktop zoom requiring pinch-and-scroll navigation. Third, PDFs cannot be updated without replacing the file, which creates version control risks -- an outdated disclosure statement is a compliance breach.
Convert your PDF disclosure to a dedicated HTML page and keep the PDF as a downloadable supplement for visitors who prefer a document they can save or print. This dual approach satisfies both digital accessibility and the subset of visitors who want a portable document. The HTML version is your primary disclosure; the PDF is a convenience copy.
Disclosure statements are not static documents. They need updating when your fee structure changes, when advisers join or leave the firm, when you add or remove product providers from your approved list, when your dispute resolution scheme membership changes, or when the regulations themselves are amended. A disclosure statement with outdated fees or departed advisers is not just stale content -- it is a potential compliance breach.
Build a review schedule into your practice operations. The disclosure page should be reviewed at minimum every six months, and updated within 30 days of any material change. The FMA's compliance expectations are clear: disclosure must be accurate and current. "We updated it when we built the website" is not an adequate compliance position.
Assign a specific person responsibility for the disclosure review -- typically the compliance officer or practice manager. Add it to your compliance calendar alongside your other regulatory obligations. Date-stamp your disclosure page with a "Last reviewed" date at the bottom. This demonstrates active maintenance to both visitors and regulators, and creates an internal accountability mechanism that makes overdue reviews visible.
The FMA's "readily accessible" standard is not met by a disclosure page that sits four levels deep in a navigation menu, or one that is labelled with jargon that a typical visitor would not recognise. "Regulatory Disclosures" means nothing to most website visitors. "Important Information About Our Services" or simply "Disclosure" is clearer.
Test your disclosure page accessibility by asking someone outside your firm -- a friend, a family member, someone with no financial services background -- to find your disclosure statement starting from your homepage. Time them. If it takes more than 30 seconds or they cannot find it without help, your navigation is failing the accessibility standard.
The recommended placement is in your footer navigation (where visitors expect to find legal and regulatory pages) and optionally in your main navigation under an "About" or "Important Information" section. Some firms also link to their disclosure statement from their contact page, which is strategically sound -- a visitor about to make an enquiry is exactly the audience that should see your disclosure before engaging.
Cross-link your disclosure page from your individual adviser profiles. A visitor reading about a specific adviser should be one click away from that adviser's disclosure information. This is not just good compliance practice -- it is the kind of transparent navigation that builds the trust your commercial pages are working to establish.
FMA website disclosure requirements are not onerous once you separate what must appear on the site from what must be available on request. A dedicated disclosure page in HTML format, a clear complaints process page, and a six-monthly review schedule cover the core obligations. The firms that handle this well treat disclosure as a trust-building opportunity rather than a compliance burden -- because a visitor who reads your disclosure and still contacts you is a higher-quality lead than one who never knew what your firm stands for.
