FCA financial promotion changes

The UK Financial Conduct Authority (FCA) is making changes to their Financial Promotions regime which means the introduction of the following changes for our consumer website (coinbase.com) and the Coinbase app in the UK:

  •  You’ll see a variety of risk warnings throughout the Coinbase website and app.

  • Coinbase will no longer offer incentive activities in relation to engagement in crypto trading activities. 

  • Coinbase will no longer offer Learning Rewards.

  • Content on the Coinbase website and app as well as our marketing materials beyond our website and app (e.g. via email, social media) will change.

Financial Promotions Regime

The Financial Promotions Regime is a set of rules by the FCA that must be followed from 8 October 2023 by all firms marketing cryptoassets to UK consumers. By this date, firms are required  to update their website, app content, and marketing materials.

From 8 January 2024, firms must also add frictions to the trading process for all users. These include a Client Categorisation, an Appropriateness Assessment test, a 24-hour cool-off period for new users, and a personalized risk warning for new users.

Impact on new and existing users

Existing users: Users whose accounts were created prior to 8 January 2024 must complete a Client Categorisation exercise and pass an Appropriateness Assessment to continue buying and trading crypto.

Users who don’t complete these steps after 8 January 2024 won’t be able to buy or trade crypto. However, they can still sell crypto for cash, send crypto to an external wallet, or withdraw cash  funds anytime, as well as explore products and browse crypto prices and news.

New users: Users who sign up after 8 January 2024  will need to complete an onboarding process that includes a Client Categorisation step, an Appropriateness Assessment, a 24-hour cooling-off period, and a personalized risk warning advising of the risks that come with trading cryptoassets.. 

These changes are required by the FCA and cannot be opted out of or accelerated.

Participation in incentives and promotions

The  Financial Promotion Regime prohibits Coinbase from offering monetary or non-monetary incentives in relation to cryptoasset trading after 8 October 2023. This includes learning rewards.

Product access

You might not be able to access certain Coinbase products if you haven't completed the FCA Financial Promotion regulation requirements. Once you meet these requirements, you can access these products and services.

Coinbase Card

Existing Coinbase Card users can continue using their card without the Appropriateness Assessment and Client Categorisation. To open a new Coinbase Card after 08 January 2024, your Coinbase account must meet the FCA Financial Promotions Regulation requirements.

Client Categorisation (applicable to new and existing users) 

Client Categorisation is a step of the Financial Promotions regime where customers self-select into one of two FCA-defined categories: Restricted Investor or High Net Worth Investor, or they must certify that neither applies. Only those who self-certify as either a Restricted or High Net Worth Investor can buy or trade cryptoassets.

A Restricted Investor has limited investment exposure, not investing more than 10% in high-risk assets in the past 12 months and not planning to  invest more than 10% of their net assets into high risk assets in the next 12 months.*

A High Net Worth Investor earns £100,000 or more per year, or has net assets worth £250,000 or more.*

The Financial Promotion regime requires all users to self-select into one of the two categories from 8 January 2024, otherwise:

  • New users can't be onboarded

  • Existing users can't buy or trade crypto assets (but can still sell crypto for cash, withdraw cash, or send crypto to an external wallet address or Coinbase Wallet)

Customers must revalidate Client Categorisation every 12 months.

* Net assets do not include primary residence, pension (or any pension withdrawals) or any rights under qualifying contracts of insurance. High-risk investments include peer-to-peer loans, investment-based crowdfunding, units in a long-term asset fund, unlisted debt and equity (such as in companies not listed on an exchange like the London Stock Exchange), and cryptoassets.

24-hour cooling-off period (new users only)

To comply with the Financial Promotion regime, new users who sign  up after 8 January 2024 must wait 24 hours before trading with Coinbase. This period can't be disabled or expedited. During this time, users can complete onboarding, browse prices, and explore some products, but cannot buy or trade.

Appropriateness Assessment

The Appropriateness Assessment is a short multiple-choice test about Coinbase’s cryptoasset trading products. It helps ensure these products are suitable for customers. As per the FCA’s Financial Promotions regime, only customers who pass this test can buy or trade cryptoassets. If you fail, you can retake it once immediately. After two failed attempts, you must wait 24 hours before retaking it. This is an FCA requirement. To learn more about cryptoassets, please read our guide.

Risk warnings

You’ll see the following FCA-mandated static, non-dismissable risk warning at the top of most pages on the Coinbase website and app: ​​“Don’t invest unless you’re prepared to lose all the money you invest. This is a high-risk investment and you should not expect to be protected if something goes wrong. Take 2 mins to learn more.”

You’ll also see new risk disclosures and data source disclaimers related to performance, market data, and asset category specific risks across our website and app.

Financial Promotion approver

Firms, such as Coinbase, that provide crypto-asset services from outside the UK require an FCA authorised firm to approve any financial promotions that they make in the UK.

The approver reviews Coinbase’s financial promotions and approves them if they meet the standards set out in the UK Financial Promotion rules.