FCA multi-firm review of CFD providers’ provision of price and value
On 13 November 2025, the Financial Conduct Authority (FCA) published a multi-firm review in relation to how contracts for difference (CFD) providers comply with their obligations under the Consumer Duty ‘Price and Value’ outcome.BackgroundThe FCA explained that this review follows on from a portfolio letter sent to CFD firms in December 2024 and considers, in particular, how CFD firms deliver fair value in areas such as bid/offer spread pricing, commissions, and overnight funding charges, as well as how firms are using their Consumer Duty (the duty) fair value assessments to deliver against the price and value outcome.Key findingsThe FCA set out examples of good and poor practice, including:
Applying the Consumer Duty and proportionality: The FCA explained that most firms were using the duty as an opportunity to review the products they offer and make improvements where necessary; however, it also found that while some firms had made changes in response to the duty that others had not and so may have failed to consider their obligations fully, and that a minority of firms’ annual board report required under the duty mainly restated requirements rather than analysing firm compliance.
Fair Value Assessments (FVAs): The FCA found that most firms conducted peer comparisons against FCA authorised competitors and provided good reasons for selection, and that the most comprehensive FVAs covered scope, analysis and justification for their conclusions considering both monetary and non-monetary factors. That said, it also found that many firms’ FVAs only gave limited consideration to costs paid by consumers other than those for executing trades whereas other costs can be a significant part of the overall price paid; some firms’ assessments considered the wrong types of peer firms; that there was a wide range of effective interest rates paid by retail clients without adequate justification or disclosure; only a few firms were paying interest on retail clients margin deposits; many firms had not considered other key indicators of value beyond execution quality; and, some firms had not fully considered if they should make any changes to their appropriateness tests, particularly having poor controls in relation to vulnerable retail clients.
Assessing the target market: The FCA highlighted that some firms had strengthened appropriateness testing as a result of the duty and that most firms considered the conflicts associated with allowing applicants who failed this test from proceeding but that some firms had made few or no duty related changes even after conducting reviews and therefore firms may want to consider how robust their current testing is.
Vulnerable clients: The FCA set out that monitoring for vulnerability characteristics during onboarding seems to be widespread as is training for client facing staff in relation to this and that some firms that had accepted vulnerable clients have managed the risk by applying vulnerability measures. However, some firms had only implemented reactive measures rather than monitoring and some firms said they had only identified few or no vulnerable clients calling into question how effectively this is being considered.
Fees and charges, including overnight funding fees: The FCA made clear that most firms had reviewed their overall charges and simplified fee structures in response; however, it also found that many firms should better consider all changes in the context of other fees and be able to demonstrate that overall costs are reasonable, that firms could improve their disclosure in relation to this to clients, that in relation to overnight funding charges specifically firms could improve how they are quoting interest rates to retail clients, and that firms may also consider reviewing key investors documents and other client communications to better highlight their charges.
Matched/hedged client positions: The FCA had observed that some firms discourage clients from holding open hedged positions due to the potential for foreseeable harm but that there were a wide variety of approaches to margining hedged open positions and it also found that there were shortcomings with disclosures in relation to the cost of keeping open positions versus closing positions.
Interest on clients’ accounts: Finally, the FCA explained that it had found that several firms had reviewed their approach on paying interest on CFD client balances but that firms may want to review if charging clients funding interest without also paying clients on margin deposits is providing fair value.
Next StepsThe FCA made clear that it encourages all firms manufacturing or distributing CFDs to retail clients to consider these findings and address any gaps, and that it is considering further work in relation to some of the areas identified.
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