What FCA Compliance Means for Your Website

Your marketing team ships a redesign on Friday. The hero section looks sharp. Body text has grown to 18px, and the risk warning in the footer has quietly become a pale grey line at 11px.

On Monday your compliance officer opens the site and finds a problem nobody on the design side knew existed.

FCA compliance for a website is not a legal appendix you add after launch. It reaches into your type scale, your colours and the position of a single banner. One rule in particular, COBS 4.5.2R, sets a typographic floor for risk warnings on a broker website, and it almost never appears in a design brief.

This article explains what the FCA expects from your pages, where each rule sits in the Handbook and what to check before you apply or launch. It is general information, not legal advice.

What FCA Compliance Means for a Website

For a website, FCA compliance means that every page that invites or induces investment activity meets the FCA's financial promotion rules. In practice, that comes down to four obligations:

• The content is clear, fair and not misleading.

• Benefits are balanced by a fair and prominent indication of relevant risks.

• Important statements and warnings are not disguised, diminished or obscured.

• The firm is allowed to communicate the promotion in the first place.

These FCA compliance requirements are about what your visitors see and read, not about licensing paperwork. Authorisation, capital and governance are separate topics, covered in our guide to what regulators check.

If you want an FCA compliance checklist you can work through page by page, start with our broker website compliance checklist, then come back here for the reasoning behind the rules.

Is Your Website a Financial Promotion?

Yes. The FCA counts websites as financial promotions. A financial promotion is an invitation or inducement to engage in investment activity that is communicated in the course of business, and the FCA lists websites alongside brochures, emails and social posts.

What the FCA Counts as a Financial Promotion

The FCA takes a media-neutral approach: the same standard applies to a homepage, a landing page, a banner ad or a post. Every one must be clear, fair and not misleading.

That standard is enforced. In 2024, authorised firms amended or withdrew 19,766 promotions following FCA interventions, up from 10,008 in 2023, according to the FCA's financial promotions data.

Here is where most teams lose time. They treat the website as brand material and only send ads to compliance. The FCA does not draw that line.

The consequences are practical. Where a promotion falls short, the FCA can require changes or removal, require the firm to contact customers who may have been misled, issue warnings or fines, or ban the promotion.

Who Can Communicate It Before You Are Authorised

Section 21 of the Financial Services and Markets Act restricts who may communicate a financial promotion. Under the FCA's approving financial promotions guidance, a promotion may be communicated if:

1. the person is an authorised person,

2. the promotion has been approved by an authorised person (a section 21 approver), or

3. an exemption in the Financial Promotion Order 2005 applies.

Since 7 February 2024, firms that approve promotions for unauthorised persons need explicit FCA permission, as the FCA explains when applying to approve financial promotions.

Risk Warnings: What the FCA Requires on Your Pages

For retail CFD products, COBS 22.5.6R requires a prescribed FCA risk warning that includes your firm's up-to-date percentage of retail accounts that lose money. Other products carry different warnings, so confirm which rule applies to what you offer.

The CFD Warning and Its Percentage Statement

The Handbook's COBS 22.5 sets the wording for retail CFD promotions: "CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage. [X]% of retail investor accounts lose money when trading CFDs with this provider."

The percentage is not a one-off number. You recalculate it every three months, covering the preceding 12 months, and it must reflect all costs, fees, commissions and charges.

Where the Warning Must Sit on the Page

The same rules govern placement. The warning must be prominent, sit within its own border and, on websites and apps, be statically fixed at the top so it stays visible while the visitor scrolls. On a website, it must also appear on each linked page. Font should be proportionate to the material and the background neutral.

In practice, that rules out a warning that scrolls away with the hero or lives only on the homepage.

COBS 4.5.2R: The Typographic Floor for Risk Warnings

COBS 4.5.2R(5) requires a risk warning to use a font size that is at least equal to the predominant font size used throughout the material. COBS 4.5.2R(4) adds that a communication must not disguise, diminish or obscure important items, statements or warnings.

You can read both in the Handbook under COBS 4.5.

The rule is relative, not absolute. The FCA does not set a pixel size. The floor is whatever your body text is. If your design system moves body copy from 16px to 18px, the minimum for your warning moves with it.

Here is what that looks like in a live design review:

Those readings are judgement calls, not FCA examples, so take the grey areas to your compliance officer.

What Financial Promotion Rules Block on a Pre-Authorisation Site

Before authorisation, financial promotion rules limit what a live site can say. A broker waiting for its licence cannot treat the website as a free-for-all just because no client has onboarded yet.

Imagine you are a founder two months from submitting your application. Marketing wants the full site live to build an audience. The site invites visitors to open an account, advertises spreads and shows a welcome bonus. Unless a route under section 21 applies, that content is exactly what the restriction targets.

The practical approach for a pre-authorisation site:

• Publish a corporate or holding page with company information.

• Keep invitations to trade, account opening forms and product claims off the live site.

• Build the full site on staging and release it once you are authorised, have a section 21 approver, or have confirmed an exemption.

Where the line sits depends on your facts, so this is a question for a compliance lawyer. The legal documents a launch needs are listed in our guide to the legal pages a forex broker needs.

A Practical Website Review Before You Apply

Run this review before you apply and again before every major redesign:

1. List every page and channel that invites investment activity, including landing pages.

2. Confirm your route to communicate: authorised, approved by a section 21 approver, or exempt.

3. Check the risk warning on each page for wording, current percentage, placement and border.

4. Compare the warning's font size with your body text on desktop and mobile.

5. Get written sign-off from your compliance officer and keep a dated record.

If you are launching in under eight weeks, build the warning component first. Everything else is easier to adjust than a warning that was bolted on late.

How WSA Builds FCA-Ready Broker Websites

WSA is a fintech-specialist web design agency that builds broker sites on Framer. We are designers, not lawyers, so we do not interpret the rules for you. We make them easy to follow.

In WSA's experience, three practices prevent most typography problems:

• The risk warning is a single reusable component, fixed to the top of every page.

• Font sizes are tokens in the type scale, so the warning cannot drop below body text.

• Compliance review is a step in the build plan, with your officer approving before launch.

The result is a site where compliance survives the next design change.

Conclusion

On a website, the rules come down to a short list of decisions: whether you may communicate the promotion at all, which warning applies, how long it stays accurate and how it looks on the page. COBS 4.5.2R turns the last one into a design rule your team can test.

Meeting FCA compliance requirements is easier when the warning is built into the system from the first sketch, not added at the end. If you are planning a broker site, WSA can build it with those rules in mind. See how we work at wsa.design.

FAQ

What does FCA compliance mean for a website?

For a website, it means every page that invites investment activity must meet the FCA's financial promotion rules. Content must be clear, fair and not misleading, risks must be shown fairly and prominently, and warnings must not be disguised, diminished or obscured. You also need a lawful route to communicate the promotion: authorised status, a section 21 approver or an exemption.

What risk warnings does the FCA require?

The required warning depends on the product. For retail CFDs, COBS 22.5.6R prescribes wording that includes the percentage of retail accounts that lose money with your firm. That figure is recalculated every three months and covers the preceding 12 months. On websites the warning must be prominent, in its own border and statically fixed at the top of each page. Other products have their own warnings, so check the Handbook for yours.

Is a website a financial promotion under FCA rules?

Yes, a website is a financial promotion if it invites or induces investment activity in the course of business. The FCA lists websites alongside brochures, emails and social media posts and applies a media-neutral standard: every promotion must be clear, fair and not misleading. A purely informational page with no invitation to invest is a different case, so confirm the position for each page.

What font size must a risk warning use?

A risk warning must use a font size at least equal to the predominant font size used throughout the material (COBS 4.5.2R(5)). The FCA does not set a pixel value, so the minimum follows your body text. If body copy is 18px, a warning at 11px falls below the floor. COBS 4.5.2R(4) separately bans disguising, diminishing or obscuring warnings.

Does the FCA review websites during authorisation?

The FCA's published guidance does not describe website review as a formal step of authorisation. It says applicants are asked whether they will approve financial promotions for unauthorised persons, and live promotions remain subject to section 21 and the COBS rules whatever the application stage. Treat your site as reviewable at any time and confirm your approach with a compliance adviser.