Marketing review: documents to prepare
Marketing review checks every promotional text, image and video before it reaches investors. A clean file moves through review far faster than one assembled at the last minute. Expect to submit a marketing pack, a risk-disclosure text, evidence for each factual claim and a distribution plan. Missing evidence is the single most common reason a file stalls after the first round.
Why the review exists
Marketing review exists because promotional material for a token offering is checked before publication under the marketing rules that apply to that stage of the offering. The check is procedural. It does not decide whether the token itself may be issued or traded. It decides only whether the marketing text meets the standard set for public communication at that point.
The review sits between drafting and publication, not before drafting and not after publication. Nothing in the marketing pack goes live until the reviewer signs it off. That single rule shapes most of the timing questions below.
What changes once review starts
Once a file enters review, the campaign timeline effectively pauses. Publication dates move. Distribution channels wait for sign-off rather than for the marketing team's own schedule. This is often the first surprise for a team that has planned a launch date around drafting time alone.
Any change made to the marketing pack after submission resets the review for the affected document only, not for the whole file. A late edit to one banner does not restart the check on the risk-disclosure text.
The point of no return sits at sign-off, not at submission. Before sign-off, a document can be withdrawn and reworked at no cost to the overall timeline. After sign-off, any change to that document requires a fresh review cycle, even a small one.
Stages, documents and typical duration
| Stage | Documents required | Typical duration |
|---|---|---|
| Intake | Marketing pack, distribution plan | 1–2 working days |
| Factual check | Evidence file for each claim | 3–5 working days |
| Risk-disclosure check | Risk-disclosure text, prior sign-off record if one exists | 2–3 working days |
| Sign-off | Final version of the marketing pack | 1 working day |
These figures describe a file with no missing documents and no open questions from the reviewer. A file with gaps runs longer, sometimes by weeks, because each round of questions restarts the clock on the affected document rather than on the whole pack.
Documents to prepare
- Marketing pack — every text, image and video intended for public use, in the form the audience will actually see.
- Risk-disclosure text — the warning language shown alongside promotional content, matched to the audience it reaches.
- Evidence file — a source for every factual claim in the pack: a report, a contract, a public register extract, a technical document.
- Distribution plan — channels, audience and timing for each piece of material.
- Prior sign-off record — if an earlier version of the same material was already reviewed, attaching that record shortens the current check.
A file missing any one of these is not rejected outright. It is parked with a specific question attached, and the clock resumes once the missing piece arrives.
What to do
- Assemble the marketing pack first, in its near-final form. Assign one named person as the single point of contact for the file.
- Contact the review team early, before the pack is final — see The people behind the reports in practice for who handles intake.
- Attach evidence to each claim while the pack is being built, not after submission. Evidence added late is the most frequent cause of a second round.
- Submit the risk-disclosure text alongside the pack, not as a separate later step.
- Track every question from the reviewer and answer within the stated window. A late answer restarts the clock on that document.
- Keep the sign-off record once issued. It shortens review for the next version of the same material and for related campaigns.
Who decides
The reviewer inside the compliance function takes the sign-off decision on each document. Where a claim cannot be evidenced in time, escalation goes to the person responsible for the offering, not to the reviewer, since the choice is commercial: remove the claim or delay the pack.
There is no external forum at this stage. The review is internal and precedes any filing with a regulator or exchange. It exists to catch problems before they reach a body that does not offer a second chance to fix them quietly.
Forks
If the marketing pack covers more than one jurisdiction, each version needs its own risk-disclosure text matched to that audience, not one text reused across all of them.
If a claim cannot be evidenced in time for the launch date, the safer path is to remove the claim rather than delay the whole pack for one line of text.
If the same material was reviewed for an earlier offering or an earlier version of the same token, attach that sign-off record. The current check then narrows to what has actually changed.
Sources and limits
This page does not decide whether a marketing claim is factually correct. It describes the procedure that checks it. The evidence behind each claim has to come from elsewhere, and the quality of that evidence is what the reviewer actually tests.
When the file touches a counterparty registered in more than one country, the same evidence question appears in reporting work: see how a report frames Counterparty in Latvia and its limits.
A single supporting document sometimes needs its own check before it can serve as evidence at all, structured along the lines set out in Document in Finland and its limits.
Cross-border distribution plans raise a parallel question at jurisdiction level, covered in Jurisdiction in Netherlands and its limits.
What this page does not cover
This page does not cover the substance of marketing rules, the token's own admission to trading, or the cost of the review work itself. It covers timing, the documents a file needs to enter review, and who takes the sign-off decision.
Verified
Last reviewed: 10 March 2025. This page draws on internal review procedure documentation. No external source is cited because the procedural stage does not rest on a numbered act or article.
FAQ
How long does marketing review take in practice?
A complete file with evidence already attached typically clears in one to two weeks. A file with gaps takes longer, because each question from the reviewer restarts the clock on the affected document rather than the whole pack.
Which documents are needed to start?
Intake needs the marketing pack and the distribution plan. Evidence and the risk-disclosure text can follow shortly after, but the reviewer will not open a full check without a plan for where each piece of material will run.
What happens if the other side does not respond?
If a reviewer's question goes unanswered past the stated window, the file is parked rather than rejected. Work resumes once the missing answer arrives, picking up from the stage where it stopped, not from the beginning.
Related publications
See also Listing preparation step by step for the stage that typically follows a completed marketing review.
Get in touch before the marketing pack is final. The earlier the review team sees a draft, the shorter the first round tends to be.