CFD risk warning wording: the FCA's exact text

Every warning below is quoted word for word from section 22.5 of the FCA's Conduct of Business sourcebook (COBS) and set as COBS 22.5 requires: bold where it says bold, in its own border, against a neutral background.

Which products and firms COBS 22.5 covers

COBS 22.5 applies to firms that market, distribute or sell “restricted speculative investments” to retail clients in or from the UK: MiFID investment firms (other than collective portfolio management investment firms), branches of third-country investment firms and Swiss firms registered under the Berne Financial Services Agreement (COBS 22.5.1R). The FCA's Glossary defines restricted speculative investments as leveraged CFDs, leveraged spread bets, leveraged rolling spot forex and restricted options. Marketing includes communicating and approving financial promotions (COBS 22.5.4G).

Cryptoasset derivatives are outside the section (COBS 22.5.5R); COBS 22.6 bans marketing, distributing or selling them to retail clients. For other derivatives with similar features, the FCA's guidance asks firms to have “particular regard” to the fair, clear and not misleading rule, the Consumer Duty and their other obligations (COBS 22.5.22G).

Three versions, by medium

Which warning a promotion carries depends on where it appears. The rules prescribe three versions.

The full warning: websites and durable media

For any communication in a durable medium or on a website that is likely to reach a retail client, the firm must include the prescribed warning (COBS 22.5.6R(1)). For a firm offering CFDs, spread bets or rolling spot forex:

A firm that also sells restricted options uses “CFDs and restricted options” throughout (COBS 22.5.6R(1B)). A firm selling only restricted options uses “Restricted options” (COBS 22.5.6R(1C)).

The abbreviated warning: other media

In any medium other than a durable medium, website or webpage, such as a display advert, a video or a social post, the abbreviated version applies:

The character-limited warning

Where the abbreviated warning is longer than a third-party marketing provider's character limit, as on some ad platforms, the firm must use:

This warning must be “accompanied by a direct link to the firm's webpage which contains the risk warning in COBS 22.5.6R” (COBS 22.5.6R(12)).

Firms with no retail trades in the last 12 months

A firm that has not entered into a single trade in a restricted speculative investment with a retail client in the previous 12 months has no percentage to calculate. It uses a fixed statement instead (COBS 22.5.7R):

In other media, the no-trades warning becomes “The vast majority of retail client accounts lose money when trading in CFDs. You should consider whether you can afford to take the high risk of losing your money.” Where that exceeds a platform's character limit, COBS 22.5.7AR substitutes “CFD-retail client accounts generally lose money.”

How to calculate the percentage

The percentage must be the firm's own and kept up to date (COBS 22.5.6R(2)–(8)):

• How often: “every three months”, covering “the 12-month period preceding the date of the calculation”.
• A losing account: one where “the sum of all realised and unrealised net profits on restricted speculative investments traded in that retail client's account during the 12-month calculation period is below zero”.
• Costs: the calculation “must include all costs, fees, commissions and any other charges”.
• Excluded: accounts with no open position in the period, profits or losses on other investments, deposits and withdrawals.
• Records: records of the accounts used must be kept for five years.

Every live promotion must carry the current figure. A banner built last quarter with last quarter's percentage is out of date once the new figure applies.

Where the warning must appear

The FCA's guidance adds that the warning, including its font size, should be proportionate to the content, size and orientation of the material, and “published against a neutral background” (COBS 22.5.9G). For MiFID business, the general rule also applies: risk text in a font “at least equal to the predominant font size” (COBS 4.5A.3R(2)(c)).

On social media, the FCA's finalised guidance treats two common shortcuts as failing its expectations: a warning truncated so that it “ceases to comply”, and a warning “found within the caption of the video”. In short-form video, a prominent warning is one “clearly and prominently displayed across the screen throughout the financial promotion” (FG24/1, paragraph 2.46).

No bonuses or incentives

Monetary incentives include “the offering of bonuses in relation to the opening of a new account or the offering of rebates on fees (including volume-based rebates)”. Lower fees offered to all retail clients are not an incentive, and nor are information and research tools (COBS 22.5.21G). So “£100 bonus when you open an account” fails, while “spreads from 0.6 points for every client” does not breach this rule.

Leverage limits

Leverage quoted to retail clients has to sit within the FCA's minimum initial margins (COBS 22.5.11R):

Retail clients also have negative balance protection: their liability is “limited to the funds in that account” (COBS 22.5.17R).

What the FCA is looking at now

The September closures followed the FCA's challenge to how those firms used their UK authorisation, which it said created “the misleading impression that consumers are dealing directly with a UK-regulated firm and benefit from UK protections when they do not” (FCA, 25 September 2026).

The October findings centre on overnight funding charges: their level, and whether firms give clients enough information about them to meet the Consumer Duty. The FCA found that “firms do not explain their costs prominently enough in the client journey”, and that only a minority of firms have improved their disclosures by adding annual percentage rates (FCA, 15 October 2026). It is supervisory guidance, not new rules.

A checklist for every CFD promotion

Connor checks CFD adverts, posts, videos and web pages against these rules and the rules of each market a promotion targets, quotes the words each finding is about and cites the rule.