Financial Journalism in the UK: Insider Rules, Conflicts & IPSO Clause 13

IPSO Clause 13: Financial Journalism

Clause 13 of the IPSO Editors' Code of Practice is specifically dedicated to financial journalism. It is one of the most precisely worded clauses in the Code and creates obligations that go beyond general accuracy requirements:

• No use of financial information for personal profit: Journalists must not use for their own profit financial information they receive in advance of its general publication, nor should they pass such information to others.
• No writing about shares in which they have an interest: Journalists must not write about shares or securities in whose performance they have a financial interest, without disclosing that interest to the editor or financial editor.
• No trading on the basis of forthcoming articles: Journalists must not buy or sell, directly or through nominees, shares or securities about which they have written recently, or about which they intend to write in the near future.
• No front-running: The prohibition on front-running (trading ahead of publication) is absolute. Even if the information is publicly available elsewhere, trading on the basis of your own forthcoming coverage is a breach of Clause 13.

Market Abuse Regulation (MAR)

The UK Market Abuse Regulation (retained from the EU's MAR following Brexit) is the primary legislation governing market abuse in the United Kingdom. It is enforced by the Financial Conduct Authority (FCA) and creates criminal and civil liability for three main categories of behaviour:

• Insider dealing: Trading on the basis of inside information — information that is precise, not publicly available, relates to a specific issuer or financial instrument, and would, if made public, be likely to have a significant effect on prices. For journalists, this means you cannot trade on price-sensitive information you learn through your reporting before it is published.
• Unlawful disclosure of inside information: Passing inside information to another person except where disclosure is in the normal exercise of your employment, profession, or duties. Journalists have a limited exemption (see below), but this does not cover tipping off friends or family to trade.
• Market manipulation: Disseminating information that gives false or misleading signals about the price or value of a financial instrument. For journalists, publishing deliberately misleading financial information to move a share price would constitute market manipulation.

The Journalism Exemption Under MAR

Article 21 of MAR provides a partial exemption for journalists. Where information is disclosed or disseminated for journalistic purposes, the assessment of whether this constitutes market abuse must take into account:

• The freedom of the press and freedom of expression in other media
• The rules and codes governing the journalism profession (including the IPSO Editors' Code)

This means that publishing a legitimate investigative article about a company — even if it causes the share price to fall — is protected, provided the journalist has acted in accordance with professional standards and has not traded on the information or deliberately manipulated the market. The exemption does not protect journalists who trade on inside information or who write misleading articles to profit from market movements.

FCA Rules and Journalist Interactions

The Financial Conduct Authority is the primary regulator of financial services firms in the UK. While the FCA does not directly regulate journalists, its rules create obligations that affect how journalists interact with the financial sector:

• Listed companies are required to disclose inside information to the market as soon as possible. If a company's press office gives you information before it has been announced to the market, you may be receiving inside information — with all the legal implications that entails.
• Authorised firms (banks, insurers, fund managers) are required by the FCA to have policies on media engagement. Their compliance departments may restrict what spokespeople can tell you and may require pre-approval of quotes.
• FCA enforcement actions are a rich source of stories. The FCA publishes Final Notices when it takes action against firms or individuals, and journalists are free to report on these. However, be cautious about reporting on ongoing investigations, as the FCA may seek injunctions to prevent premature disclosure.

Conflicts of Interest

Managing conflicts of interest is fundamental to credible financial journalism. Common conflicts include:

• Personal shareholdings: If you own shares in a company, you must not write about that company without disclosing your interest. Many publications maintain registers of staff financial interests and require journalists to clear trades with the editor.
• Family connections: A spouse or partner working for a company you cover creates a potential conflict. Disclose this to your editor and consider recusing yourself from coverage of that company.
• Freebies and hospitality: Accepting gifts, trips, or hospitality from financial services firms can compromise your independence. Most publications have policies on what can and cannot be accepted — follow them strictly.
• Side work: Some financial journalists supplement their income with corporate copywriting, conference speaking, or consultancy. This can create conflicts if your paid clients overlap with companies you cover editorially.

Sponsored Content and Disclosure

The rise of “native advertising” and sponsored content in financial media has created new challenges for journalists and editors:

• Clear labelling: Under IPSO and ASA rules, sponsored content must be clearly distinguished from editorial content. Labels such as “sponsored,” “advertisement feature,” or “paid partnership” must be prominent and unambiguous.
• FCA financial promotions rules: If sponsored content constitutes a “financial promotion” (i.e., it communicates an invitation or inducement to engage in investment activity), it must comply with the FCA's financial promotions regime. This requires approval by an FCA-authorised person and specific risk warnings.
• Editorial independence: Journalists should not write sponsored content about companies they also cover editorially, and editorial decisions should never be influenced by advertising relationships. The NUJ Code of Conduct explicitly requires journalists to resist attempts by advertisers to influence editorial content.

Whistleblowers in Financial Services

Financial services whistleblowers are a critical source for accountability journalism, and the regulatory framework specifically encourages them to come forward. FCA-regulated firms above a certain size are required to have a whistleblowing champion and an internal reporting mechanism, and the FCA and the Prudential Regulation Authority (PRA) both operate confidential whistleblowing lines that accept reports directly from employees of regulated firms.

• Legal protection: The Public Interest Disclosure Act 1998 (as amended) protects whistleblowers from detrimental treatment by their employer where they make a “protected disclosure” about matters including breaches of legal or regulatory obligations. This protection is separate from, and does not depend on, whether the whistleblower also speaks to a journalist.
• Source protection is still paramount: Legal whistleblower protections reduce but do not eliminate the practical risk to a source's career and reputation. Apply the same source protection discipline described in our digital security guide to any financial whistleblower relationship.
• Corroboration: Financial whistleblower accounts should be corroborated with documentary evidence wherever possible — regulatory filings, internal emails, or Companies House records — both to strengthen the story and to protect against Clause 13 and defamation risk.

Crypto and Digital Assets

The rapid growth of cryptocurrency and digital asset markets has created a new frontier for financial journalism — and new regulatory challenges:

• FCA crypto regulation: Since January 2024, crypto firms marketing to UK consumers must comply with the FCA's financial promotion rules. Journalists should be aware that some crypto press releases and PR materials may themselves be non-compliant financial promotions.
• Personal holdings: If you hold cryptocurrency, the same Clause 13 principles apply as for traditional shares. Do not write about tokens you own without disclosure, and do not trade ahead of your own articles.
• Verification challenges: The crypto sector is rife with misinformation, pump-and-dump schemes, and fraudulent projects. Apply the same verification standards you would to any financial story — and be especially sceptical of claims made in press releases from unregulated entities.
• NFTs and digital collectibles: These are an emerging area where the regulatory framework is still developing. The FCA has indicated that some NFTs may be classified as regulated financial instruments, depending on their characteristics.

Embargoes, RNS Announcements and Results Day Reporting

Listed companies release their most price-sensitive information through the Regulatory News Service (RNS), the London Stock Exchange's official channel for regulatory announcements. Understanding how RNS releases work is essential for any journalist covering listed companies, because it defines the precise moment information becomes public and therefore the moment your reporting stops carrying inside-information risk.

• Embargoed results and briefings: Companies frequently brief journalists on results ahead of the market-facing RNS release, under strict embargo until the RNS goes live. Breaking an embargo is both a serious professional breach and potentially a market abuse issue if it allows any recipient to trade ahead of general publication.
• Analyst briefings: Journalists sometimes attend the same results calls as sell-side analysts. Anything said on these calls before the RNS has gone out is, in substance, inside information — treat it accordingly even if the company's press office has not explicitly said so.
• Leaked results: If you receive company results ahead of the scheduled announcement from an unauthorised source, publishing them can itself move the market ahead of the company's official disclosure obligations. Consult your editor and consider whether early publication serves a genuine public interest or simply a competitive scoop.

Practical Tips for Financial Journalists

1. Maintain a personal trading register: Keep a log of all your financial holdings and trades. Many publications require this; even if yours does not, it protects you against allegations of improper trading.
2. Declare conflicts early: If a conflict arises, tell your editor immediately. It is far better to be transparent and recuse yourself than to have a conflict discovered later.
3. Understand the companies you cover: Read annual reports, regulatory filings, and Companies House records. Financial journalism requires a level of technical understanding that general reporters may not have — invest in your own training.
4. Be cautious with “tips”: Tips from sources within companies may constitute inside information. If you receive potentially price-sensitive information, consult your editor and legal team before trading or publishing.
5. Separate opinion from fact: Financial commentary and analysis are legitimate, but they must be clearly distinguished from factual reporting. Label opinion pieces clearly and ensure any forecasts or recommendations include appropriate caveats.
6. Know the FCA register: The FCA Register is a free, searchable database of authorised firms and individuals. Use it to verify whether a company or individual is regulated.

Practical Checklist

Run through these before filing any story involving listed companies or your own investments:

• Check your personal trading register for any holding in the company you are about to cover
• Confirm any embargoed briefing information has actually been released via RNS before publishing
• Disclose any personal shareholding or family connection to your editor before the story runs
• Verify the FCA register if the story involves an individual or firm claiming to be authorised
• Label sponsored or native content clearly and separately from editorial coverage of the same company
• Flag any crypto holdings you have in a token or project you are covering, per your outlet's disclosure policy
• Keep dated notes of when you received any potentially price-sensitive tip and from whom

Common Mistakes

• Assuming Clause 13 has a public interest override: It does not — the prohibition on trading and disclosure is absolute, unlike most other clauses in the Editors' Code.
• Confusing the MAR journalism exemption with a licence to trade: Article 21 is a defence to market manipulation, not insider dealing — it never protects trading on inside information.
• Publishing embargoed results early without checking the RNS timestamp: Jumping the gun on an embargo can itself create market abuse exposure, not just a professional breach.
• Treating crypto holdings differently from share holdings: The same conflict-of-interest logic applies; failing to disclose token ownership before writing about a project is a Clause 13-equivalent breach in substance.
• Not verifying FCA authorisation before quoting a financial adviser or firm: Unregulated entities posing as authorised advisers are a recurring source of consumer harm stories — and of embarrassment if you unwittingly promote one.

Red Flags to Watch For

• A source offers you information about a listed company alongside an unsolicited trading tip
• A company press office asks you to hold a story until a specific time without explaining the RNS timing rationale
• You are asked to write sponsored content about a company you also cover editorially
• A crypto press release contains claims that would constitute a financial promotion without visible FCA-compliant risk warnings
• A colleague's published articles consistently precede unusual trading volume in the stocks they cover

Further Resources

• IPSO Editors' Code 2025 — Full Clause 13 text and guidance
• Full text: UK Market Abuse Regulation
• Defamation Law for UK Journalists — Protecting yourself when reporting on companies
• UK Journalism Ethics Codes — NUJ and IPSO guidance