UK: FCA CFD firms review: fair value and overnight funding charges under scrutiny

The FCA has published findings from a follow-up survey of 81 contracts for difference (CFD) firms on the Consumer Duty price and value outcome. It sets out good practice and areas firms should consider further, with particular concern about overnight funding charges and how firms explain them.

Why should I read this?

On 15 October 2026, the FCA published its webpage “Contracts for difference firms: good and poor practice”. It follows the FCA’s November 2025 multi-firm review of CFD providers’ provision of price and value. In May 2026, the FCA asked 81 CFD firms, of all sizes and representing about a quarter of the market, whether they had made any changes as a result. The webpage shares the findings from that survey.

The Consumer Duty price and value outcome requires manufacturers to ensure their products provide fair value to retail customers in the target market for those products. Manufacturers must also carry out a value assessment of its products and review that assessment on a regular basis appropriate to the nature and duration of that product.

The FCA found that most firms had made changes or planned to, but many changes were relatively minor and had not fundamentally altered firms’ provision of price and value. The FCA still has concerns, particularly about the level of overnight funding charges, how firms apply them (including to matched or hedged positions) and whether clients get enough information about them.

The webpage does not create new rules. It is relevant to all FCA-authorised investment firms that manufacture, promote or distribute CFDs, spread bets or rolling spot forex to retail clients. The FCA expects firms to be able to show that they have reviewed their charges and will follow up with individual firms if it has concerns.

What should CFD firms do?

Review your overnight funding charges against fair value

Check whether any of your rates are outliers against prevailing base rates and UK peers. Consider how you apply charges to matched or hedged positions, and whether charging the full funding spread on those positions can be justified.

Make your fair value assessments focus on outcomes, not compliance

Include all costs and charges applied to client accounts. Compare yourself with UK regulated providers rather than offshore or global firms. Do not treat the assessment as a tick-box exercise designed to conclude you deliver fair value.

Explain your charges earlier and more prominently

Do not rely only on terms and conditions or KIDs. Consider dedicated, clearly signposted fee pages, pop-ups and deal ticket information. Show overnight charges as a projected annual percentage as well as a daily cost.

Review how you promote matched or hedged positions

If you offer reduced or waived margins for matched trades, give clients a clear, balanced view of the pros and cons compared with simply closing the positions.

Keep a record of your review

The FCA expects firms to be able to show that they have reviewed their charges. Document your conclusions and any changes, and act promptly.

Nearly 3 years since the introduction of the Duty and 6 months after their feedback, the FCA is disappointed that firms have not acted faster.

What else do I need to know about the CFD firms review?

Why the FCA is focusing on CFDs

CFDs are considered high-risk investments due to the potential for the leverage they provide, magnifying both trading losses and other costs. Providers of CFDs deal directly with clients who mainly trade without advice, so dealing spreads and charges for holding open positions are key parts of the price and value proposition. Providers decide what clients pay and benefit directly from those decisions. The FCA says this sets up clear conflicts of interest which, if not managed properly, may mean clients do not get fair value.

Fair value assessments and peer group comparison

Good practice	Poor practice
Most firms amended their assessments to include all costs and charges applied to client accounts, rather than focusing on execution costs, dealing charges and service offerings.	Changes often designed to show compliance rather than materially change the offering.
Several firms moved to peer comparisons with UK regulated providers.	Some firms made no material changes while remaining clear outliers for some charges, particularly overnight funding fees.
	Assessments treated as a tick-box exercise.

Appropriateness testing and vulnerability monitoring

Good practice

Several firms amended their onboarding. Changes included introducing an income threshold below which consumers are not accepted or face enhanced scrutiny at the appropriateness test stage, reviewing target markets and enhancing vulnerability monitoring.

Client disclosures and information

Good practice	Poor practice
Firms had dedicated, clearly signposted web pages and pop-ups or overlays explaining fees, how much they are and how they are calculated.	Firms did not explain costs prominently enough in the client journey, often only in terms and conditions or KIDs.
Some firms included or enhanced charges information on deal entry tickets. A minority added annual percentage rates to the implied daily cost of overnight financing.	Overnight charges on deal tickets were not always shown as a projected annual percentage.
	Mark-ups in overnight funding charges remain largely opaque.

Firms should consider the information they will be required to give under the Consumer Composite Investments (CCI) framework that will replace KIDs.

Levels of charges and interest on cash balances

Good practice	Poor practice
12% of firms changed their charges by introducing: - interest on cash balances, - reduced overnight financing on matched or hedged positions and on outlier product groups after peer comparison, and - changed calculation methods to recognise that financing is charged on total notional with no interest paid on initial margin.	Most firms did not change their charges after reviewing them and only gave more information about existing rates.
	Overnight funding fees vary considerably and some seem high against base rates and peers, with wide spreads on long and short positions.
	Most firms apply the full funding spread to matched or hedged positions, often justified as an administration charge.

Next steps

The publication is not a consultation and sets no deadline. However, the FCA strongly recommends firms review its findings and consider whether they need to change anything to meet their price and fair value obligations. It will continue to monitor how firms apply and communicate CFD trading charges and will follow up with individual firms where it has concerns.

How ES can help

Eversheds Sutherland can help firms:

benchmark their price and value framework against the FCA’s findings
review fair value assessments, peer group comparisons and overnight funding charge methodologies
review client disclosures, fee pages, deal tickets and CCI disclosures
review appropriateness testing, target markets and vulnerability monitoring
prepare for FCA follow-up on charges

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