Only about ten of the 81 contracts-for-difference firms surveyed by the Financial Conduct Authority said they had changed any charges after the regulator’s first industry review, an FXBrokers.ai calculation shows.[1]
The FCA reported that 12 per cent of respondents had changed, or planned to change, charges. Applying that rounded percentage to the 81-firm survey produces 9.72 firms—approximately ten. The corresponding estimate is that roughly 71 did not report a charge change, although the FCA did not publish an exact firm count and its percentage may be rounded.[1]
Most respondents had altered assessments, communications or onboarding in some form. The much smaller charging response is the important distinction. The regulator said most firms had not changed the level of charges after reviewing them and had instead concentrated on providing more information about existing rates.[1]
The finding is nationally significant for the UK retail leveraged-trading market because overnight financing can become one of the largest recurring costs of a CFD. The FCA says most surveyed firms continue to apply funding charges to matched or hedged positions and that most use the same full funding-charge spread applied to genuine directional long or short exposure.[1]
That means a customer who holds offsetting long and short CFDs on the same asset can continue paying funding on both gross positions even though the trades largely cancel each other’s market exposure.[1]
The FCA has not ruled that every such charge is unlawful or that every respondent breached the Consumer Duty. Its language is deliberately qualified: the level and application of charges “may not” be consistent with price-and-value obligations, and disclosure may be insufficient to meet consumer-understanding obligations. It intends to follow up individually where it has concerns.[1]
The investigation therefore establishes a limited but consequential point. Nearly three years after the Consumer Duty took effect, and six months after the FCA’s initial feedback, only a small minority of surveyed firms said they had changed charges themselves.[1]
Twelve per cent is not the same as twelve firms
The FCA asked 81 firms in May 2026 whether they had made changes after its November 2025 multi-firm review. It later reported that 12 per cent had changed any charges.[1]
Because 12 per cent of 81 is not a whole number, the published percentage cannot be converted into a certain count without the regulator’s underlying data. Ten firms would represent 12.35 per cent of the sample. Nine would represent 11.11 per cent. If the FCA rounded to the nearest whole percentage, ten is the more likely count, but the public document does not confirm that methodology.[1]
For the same reason, “about 71” is an estimate, not a disclosed result.[1]
The denominator also needs care. The FCA says the survey included some firms without retail offerings. The 81 respondents therefore should not automatically be described as 81 identical retail CFD providers or treated as a complete census of the UK market.[1]
Even with those limitations, the scale of the response is clear. A minority changed pricing. Most did not.[1]
The changes reported by the 12 per cent included introducing interest on cash balances, reducing overnight charges on matched positions, reducing outlier charges for some underlying-product groups after peer comparisons, and changing calculation methods to recognise that financing is charged on total notional while no interest is paid on the client’s initial margin.[1]
The FCA did not disclose how many firms adopted each measure, how large the reductions were, or whether changes applied to all customers and products.[1]
Why charging on full notional amplifies the cost of leverage
A CFD gives a customer economic exposure to an underlying asset without requiring the full notional value to be paid upfront. The client posts margin, while the provider calculates gains, losses and charges by reference to a larger exposure.[1]
A simplified overnight-funding formula is:[1]
daily funding charge = notional exposure × annual funding rate ÷ day-count basis[1]
The relevant firm may use a benchmark rate plus or minus a mark-up, product-specific adjustment, weekend multiplier or another methodology. The FCA says those mark-ups remain largely opaque and that charges vary considerably between firms and across underlying assets.[1]
Charging on full notional creates a leverage effect in the cost itself.[1]
If required margin is 20 per cent of notional, a funding rate measured against the full notional is five times as large when expressed relative to the margin committed by the customer. At 10 per cent margin, it is ten times as large. That does not mean the firm’s stated annual funding rate is mathematically incorrect; it means the cost relative to the customer’s cash at risk can be much larger than the headline rate suggests.[1]
The FCA specifically noted that financing is currently charged on total notional without interest being paid on the initial margin posted by clients. Only some firms said they had changed their calculation methods to recognise that asymmetry.[1]
Market gains or losses can dwarf funding over a short holding period. Over weeks or months, however, repeated daily charges compound the cost of maintaining a position and can materially alter the break-even move required for the trade to be profitable.[1]
Matched positions expose the gross-charging mechanism
Consider a customer holding a £10,000 long CFD and an otherwise identical £10,000 short CFD on the same asset. Ignoring execution differences, the net directional exposure is close to zero. The gross open exposure is £20,000.[1]
If a provider funds each leg separately, the customer may incur the applicable long-position charge on one £10,000 position and the short-position charge or reduced credit on the other. The customer can also have paid the spread to open both legs and may pay again when closing them.[1]
The FCA says most respondents apply overnight funding charges to matched or hedged positions. Many firms justified this as an administration charge, but most used the same full funding-charge spread as for genuine directional exposure.[1]
This does not prove that every matched trade is economically costless to the provider. A firm can face platform, hedging, capital, liquidity, operational and counterparty costs. Positions may not be perfectly matched in size, timing, currency or product terms. A provider may manage exposure at portfolio level rather than offset each customer’s two trades directly.[1]
The regulatory question is whether charging the full directional funding spread on both legs delivers fair value and whether the firm can substantiate the price by reference to the benefits and costs of the service.[1]
The communication issue is equally important. Some providers offer reduced or waived margin for hedged positions, which can encourage customers to leave both trades open. The FCA says firms should explain the advantages and disadvantages of that approach compared with closing the positions and realising the resulting profit or loss.[1]
A margin benefit can therefore coexist with a funding disadvantage. Without a clear projected cost, a customer may focus on the lower immediate margin requirement while underestimating the recurring charge on gross exposure.[1]
Daily percentages obscure annual economics
The regulator found that only a minority of firms had improved disclosures by adding annual percentage rates to the implied daily percentage cost of overnight funding. Mark-ups remained largely opaque.[1]
A daily rate can appear small even when repeated through a long holding period. Annualising it does not predict the exact cost of a trade—rates and positions can change—but it creates a common comparison point with borrowing rates and competitors.[1]
The FCA said firms often place information in terms and conditions or Key Information Documents and do not always show projected annual percentages even where charges appear on deal tickets. It recommends earlier, more prominent information through dedicated web pages, pop-ups, overlays and transaction-entry screens.[1]
A robust disclosure would allow a customer to identify at least five things before opening a trade:[1][2]
• the benchmark or reference rate; • the firm’s mark-up or deduction; • whether the calculation uses full notional or another base; • the treatment of long, short and matched positions; and • the estimated daily and annualised monetary cost at the contemplated position size.[1][2]
The FCA’s publication does not say that every firm fails all five tests. It documents an industry-wide pattern of inconsistent rates, limited annualisation and opaque mark-ups.[1][2]
The first review had already identified the mechanism
The May 2026 survey followed the FCA’s November 2025 multi-firm review of CFD price and value.[1][2]
That earlier work found wide variations in effective overnight rates, inadequate justification for some differences, and disclosures that often did not make the overall effect clear. It also found matched long and short positions being charged separately, potentially creating substantial ongoing costs even where clients had little net market exposure.[2]
The FCA said most firms did not pay interest on retail CFD margin balances, even while customers paid substantial interest on the full underlying consideration of long positions. Higher market rates had increased the opportunity cost of that asymmetry.[2]
The follow-up therefore was not the first notice to the industry. The October 2026 findings measure the response after the regulator had publicly explained the concern.[2][1]
Most firms did respond administratively. They broadened fair-value assessments, improved peer comparisons, changed communications or considered onboarding and vulnerability controls. The regulator’s criticism is that many changes did not fundamentally alter the price and value delivered to customers.[1]
What the FCA has and has not found
The FCA has found that some charges appear high compared with prevailing base rates and peers; that most respondents charge matched positions; that mark-ups are largely opaque; that only a minority disclose annual percentage equivalents; and that only 12 per cent reported changing charges.[1]
It has not published firm names, rate tables, exact customer losses, revenue earned from overnight funding, or a finding that each surveyed firm breached a rule.[1]
That absence prevents a broker-by-broker ranking or a calculation of the aggregate amount paid by UK customers. It also means no individual company should be accused on the basis of the industry survey alone.[1]
The regulator says it expects firms to demonstrate that they have reviewed their charges and will follow up individually where concerns remain. That creates a clear evidential next stage: firm-specific assessments, supervisory action or enforcement may establish whether particular practices fail the Consumer Duty.[1]
A disclosure standard would make the market measurable
The investigation identifies a practical policy gap. The FCA can compare confidential submissions, but customers and independent researchers cannot readily compare the market because providers use different terminology, benchmarks, day-count conventions, product groupings and presentation formats.[1]
A standardised disclosure could require providers to publish machine-readable overnight financing data for representative products and scenarios, including matched positions. It could show the benchmark, mark-up, notional base, long and short treatment, weekend convention, daily amount and annual percentage equivalent.[1]
That would not prescribe a single price. It would make price competition and fair-value analysis more credible.[1]
The regulator has not proposed that exact system in the October publication. It is an implication of its findings: when mark-ups are opaque and only a minority annualise daily charges, customers cannot easily test whether an apparent low-spread broker is expensive to hold overnight.[1]
What this investigation establishes
The FCA surveyed 81 firms. Twelve per cent—approximately ten, subject to rounding—said they had changed any charges after the regulator’s prior review. Approximately 71 therefore did not report a charge change, although the exact count is not disclosed.[1]
Most firms continued to charge overnight funding on matched or hedged positions, commonly using the same full funding spread applied to directional exposure. Only a minority added annual percentage rates to daily-cost disclosures, while mark-ups remained largely opaque. Financing was generally calculated on total notional, with no interest paid on initial margin.[1]
The regulator has not declared all such pricing unlawful. It has said the practices may be inconsistent with Consumer Duty obligations and that it will pursue firms individually where necessary.[1]
For customers, the consequence is immediate: the spread advertised at entry is not enough to compare CFD providers. The financing base, rate, mark-up, margin treatment and cost of maintaining matched positions can determine whether a trade remains economically viable.[1]
For the industry, the message is more severe than a request for clearer small print. After a formal review and follow-up survey, most firms changed their explanations rather than their prices. The next test is whether the FCA’s individual follow-up turns that disclosure exercise into measurable changes in customer outcomes.[1]
Sources & further reading
- Contracts for difference firms: good and poor practice Financial Conduct Authority · 15 Oct 2026 · Accessed 9 Nov 2026
- Multi-firm review of contracts for difference providers’ provision of price and value Financial Conduct Authority · 13 Nov 2025 · Accessed 9 Nov 2026