If you've ever been asked to tick a box confirming you're a high-net-worth or sophisticated investor before a startup deck lands in your inbox, you've met the financial-promotion regime. It's the rule that decides who can legally be shown an unlisted-company pitch. For a couple of months in early 2024 it changed, then it changed back - and the wreckage of that U-turn is still cluttering search results, advice articles and onboarding forms today.
So here's the clean version. What the exemptions are, what the January 2024 changes did, why they were pulled in March, and the parts that survived the reversal. Get those four things straight and you'll know where the line actually sits now.
The thresholds went up, then came straight back down. The wording changes didn't.
What the exemptions actually do
Start with the rule they're an exemption from. The financial-promotion restriction makes it an offence to invite or induce someone into an investment unless the promotion is made or approved by an FCA-authorised firm, or unless an exemption applies. Most early-stage angel deals aren't approved by an authorised firm, so they lean on an exemption to be shown to you at all.
Two carve-outs matter for angels. The high-net-worth individual exemption covers you if your income was at least £100,000 in the last year, or your net assets are at least £250,000 - excluding your main home, your pensions and any life-insurance or death benefits. The self-certified sophisticated investor exemption covers you if you meet one of a short list of experience tests, such as having been a member of an angel network for six months, or having made more than one investment in an unlisted company in the last two years.
One point to hold onto: these are exemptions from a promotion rule. They let someone show you a deal. They don't authorise that person, vouch for the company, or remove a scrap of the investment risk. You can read the FCA's own summary on its high-net-worth and sophisticated investor page.
The January 2024 changes
On 31 January 2024 the rules tightened, and the headline was the money. The high-net-worth income test jumped from £100,000 to £170,000, and the net-assets test from £250,000 to £430,000. The stated aim was consumer protection: the original figures dated from 2005 and, the argument went, inflation had quietly let far more people self-certify than was ever intended. On paper a teacher near the top of the pay scale, or a homeowner with a modest pension pot set aside, could clear the old bar without ever having put money into a private company.
The wording changed too. The investor statements people sign were reworked into a clearer, more prescriptive format, and the prescribed risk-warning language was brought into line with the FCA's wider high-risk-investment rules. A new obligation was added on the other side of the table: the promoting business now had to put its own details on the communication, so an investor could see exactly who was behind the pitch rather than receiving an anonymous forwarded deck.
The March 2024 reversal
The threshold rise landed badly. Angel networks, founder groups and the wider tech sector warned that pushing the bar to £170,000 of income and £430,000 of assets would shut a large slice of would-be angels out of the market overnight - and would hit women and investors outside London and the South East hardest, because their headline numbers tend to be lower. Early-stage companies, the argument ran, would lose access to exactly the smaller cheques that get a first round closed.
The government listened. In March 2024 it announced that the financial thresholds would be put back to their previous levels: £100,000 of income or £250,000 of net assets. That reversal is why, if you check today, the numbers look identical to the ones in articles written years ago - and why so much of the online commentary about a permanent rise is now simply wrong. The whole episode lasted barely six weeks from rise to retreat, which is unusually fast for a financial rule and a fair warning of how quickly this corner of the rulebook can move.
What stayed in place
Here's the part the search results tend to miss. Only the financial thresholds were reversed. The other January 2024 changes stayed, and they still apply:
- The statement format. The reworked high-net-worth and sophisticated-investor statements remained, so the exact wording you self-certify against is the newer version, not the pre-2024 one.
- The risk-warning rules. The prescribed risk warnings that align these promotions with the FCA's high-risk-investment regime stayed put.
- Naming the promoting business. The promotion still has to carry the details of the business behind it, so you can see who is actually communicating with you.
The net effect: today's thresholds are the old, lower ones, but the paperwork and the warnings around them are the newer, stricter version. That mix is the source of most of the confusion you'll see online.
A note on what this isn't
This piece explains a rule, not your situation. Clearing an exemption means a deal can legally be shown to you; it says nothing about whether that deal is any good, and unlisted early-stage companies remain among the most likely investments to lose you everything you put in. Self-certifying is your responsibility, and getting it wrong has consequences. The figures and wording here are current as far as we know, but this regime has already moved once in a single quarter - so confirm the position with the FCA and, on any tax-relief schemes attached to a deal, with HMRC's guidance at GOV.UK, and take FCA-regulated advice before you commit capital.
Frequently asked questions
Were the sophisticated and high-net-worth investor rules reversed?
Partly. The threshold rises announced in January 2024 were reversed in March 2024, so the financial figures went back to their previous levels. But the other January 2024 changes were not reversed: the reworked statement format, the prescribed risk-warning wording and the requirement to name the promoting business all stayed.
What are the current financial-promotion thresholds?
For the high-net-worth individual exemption, income of at least £100,000 in the last year, or net assets of at least £250,000, excluding your main home, your pensions and any life-insurance or death benefits. The self-certified sophisticated investor route is separate and based on experience tests rather than money.
What changes from 2024 stayed in place?
Three things. The reworked high-net-worth and sophisticated-investor statement format, the prescribed risk warnings that align these promotions with the FCA's high-risk-investment rules, and the requirement that the promoting business puts its own details on the communication so you can see who is behind it.
Why is there so much conflicting information online about the thresholds?
Because the rules moved twice in early 2024. The thresholds were raised at the end of January and reversed in March, so articles written in between, and some written afterwards, report the higher £170,000 and £430,000 figures that no longer apply. Today's thresholds are the lower ones, but the newer statement and warning rules sit on top of them.
Does qualifying for an exemption mean a deal is safe?
No. This is general information, not financial advice. The exemptions decide who can legally be shown an unlisted-company promotion; they do not authorise the person showing it, vouch for the company, or reduce the investment risk, which remains high. Confirm the current rules with the FCA and GOV.UK and take FCA-regulated advice before committing any money.