Forex risk warnings: what the wording must say, by region
The words are set by the broker's regulator, and the loss percentage is the broker's own figure. An IB's job is to carry that warning unchanged, in every language, where no reader can miss it.
The short answer
A forex risk warning is the statement that tells a retail reader, before they act, that leveraged forex and CFDs can lose them money quickly. In the EU and the UK the wording is prescribed, includes the broker's own percentage of retail accounts that lose money, and must be displayed prominently14. Australia's CFD order sets no standard wording5; the DFSA, which regulates the Dubai International Financial Centre, requires a loss percentage in writing before an account is opened8. The words come from the broker's regulator, usually via the broker: an introducing broker should carry that approved wording unchanged, in every language they publish in.
- Under EU and UK rules the warning has three parts: CFDs are complex and leveraged; the broker's own percentage of retail accounts that lose money; and a prompt to consider whether the reader can afford the risk14.
- The percentage is recalculated every three months over the previous twelve, so it belongs to one broker at one time. It is the broker's figure to state, never the IB's to estimate or borrow1.
- Display is part of the rule: at least the main font size and in the page's language in the EU; a bordered box fixed at the top of the screen in the UK14.
- Rules differ by country. This article describes them and is not legal advice: the version that counts is the one the broker's compliance team approves.
On this page · 14 sections
- What a forex risk warning is
- Why an IB's page and ads need one
- What the wording must contain, by region
- European Union: ESMA's standardised warning
- United Kingdom: the FCA's COBS 22.5
- Australia: no set wording, strict advertising standards
- The Gulf: the DFSA in the DIFC
- The percentage belongs to the broker
- A worked example: placing the warning on an IB page
- Where a warning fails
- What this means for an IB
- The warning, checked
- Questions
- Sources
What a forex risk warning is
A risk warning is a plain statement that a product can lose the reader money. The leveraged forex an introducing broker refers clients to is typically offered as rolling spot forex or as CFDs on currency pairs. ESMA treats rolling spot forex as a CFD2, and the UK rules list it beside CFDs and spread bets4. So the forex warning is the CFD warning.
The regulator writes the words, the broker adds its own loss figure, and the IB carries the result to readers who have not reached the broker yet. This article describes the main regimes; it is not legal advice, and the version that counts is the one the broker's compliance team approves.
Why an IB's page and ads need one
The rules bind the firm that provides the product. ESMA's measure let CFDs be marketed to retail clients only if the provider sent no communication, directly or indirectly, without the warning, and it prohibited knowingly taking part in getting around that, including by acting as a substitute for the provider1. Whether an IB's page is the broker's indirect communication is a legal question for the broker; the wording shows why brokers care what partners publish.
And the reader meets the IB first. A trader who taps an affiliate link reads the IB's words before the broker's; if the warning is missing there, they decide without it. The wider standard for what an IB page may claim and must disclose is set out in evidence before claims.
What the wording must contain, by region
| Regime | Applies to | Must contain | Must be shown | Source |
|---|---|---|---|---|
| European Union | EU-authorised firms' retail CFD and rolling spot forex business | Complexity and leverage; the provider's own loss percentage; consider whether you can afford the risk | Prominent, at least the main font size, in the communication's language | ESMA Decision 2018/796, Annex II1; national measures3 |
| United Kingdom | Retail CFDs, spread bets and rolling spot forex, in or from the UK | The same three parts; set fallbacks for firms without a figure and for character limits | Prominent, in its own border, fixed at the top of the screen, on every linked page | FCA Handbook, COBS 22.54 |
| Australia | Retail CFDs | No prescribed wording in the CFD order | Advertising guidance: prominent on first viewing, same language, not left to a link | ASIC CFD order5; RG 2347 |
| Dubai (DIFC) | Firms opening retail accounts in Restricted Speculative Investments | Complexity and leverage; the product and its underlying; the 12-month loss percentage | In writing, stand-alone, before the account opens; updated at least quarterly | DFSA Rulebook, COB 6.16.48 |
European Union: ESMA's standardised warning
ESMA applied its CFD measure from 1 August 20181. By 31 July 2019 every national regulator had adopted permanent measures mostly mirroring it, and in February 2026 ESMA restated that CFDs remain subject to a mandatory risk warning under them3. The webpage version has three sentences: CFDs are complex and carry a high risk of losing money rapidly due to leverage; the provider's percentage of retail investor accounts that lose money with it; and a prompt to consider whether the reader understands CFDs and can afford the risk. Other media take an abbreviated version. The warning must be laid out to ensure its prominence, at least as large as the predominant font, in the communication's language1.
United Kingdom: the FCA's COBS 22.5
COBS 22.5 applies to firms marketing CFDs, spread bets and rolling spot forex to retail clients in or from the UK, and uses ESMA's three-sentence pattern with the firm's own percentage. A firm with no retail trades in the previous 12 months says instead that the vast majority of retail accounts lose money. Where a third-party platform's character limit is too tight even for the short version, a one-line warning giving the percentage is used, with a direct link to the full warning4.
The display rules are the strictest of the four: prominent, in its own border, statically fixed at the top of the screen on a website or app, and on each linked page4. Who may publish a UK financial promotion at all is covered in evidence before claims.
Australia: no set wording, strict advertising standards
ASIC's CFD order, in force since 29 March 2021, limits leverage and inducements, but ASIC chose not to require issuer-specific risk warnings5. The order expires on 23 May 2027 unless it is remade6. The standard for warnings comes from ASIC's advertising guide, reissued in June 2026: prominent enough to be understood on first viewing, not buried in fine print, in the same language as the advert, and not left to click-through links, particularly on platforms such as Facebook and Instagram. It adds that social media influencers who promote financial products must make sure their material is not misleading7.
The Gulf: the DFSA in the DIFC
Of the Gulf regulators, this article checked only the DFSA, the independent regulator of financial services in the Dubai International Financial Centre; the UAE's Securities and Commodities Authority and Saudi Arabia's Capital Market Authority were not checked, and nothing here describes their rules. The DFSA's rule concerns account opening, not advertising. Before a retail account for Restricted Speculative Investments is opened, the firm gives a written, stand-alone warning that names the product and its underlying and states the percentage of retail accounts that lost money over the previous 12 months, updated at least quarterly8.
The percentage belongs to the broker
The EU and UK figure is not an industry average. It is recalculated every three months over the preceding 12, counts an account as losing if its net result over the period is negative after all charges, and leaves out inactive accounts, deposits and withdrawals14. Three things follow for an IB. The figure changes quarterly, so a hard-coded one goes stale. It belongs to one provider, so another broker's number misstates yours. And a provider with no recent retail trades has none: the EU text then gives a standard range of 74–89%, the UK text says the vast majority14.
A worked example: placing the warning on an IB page
Gravity's own worked example, illustrative: an educator publishing in Arabic and English refers clients to a broker authorised in an EU country, which supplies its approved warning in both languages and a new figure each quarter. No real firm or figure is used.
Top of the page
The broker's full warning in a bordered band at the main text size, visible before any scrolling, with [broker's current figure]% in place.
Beside the account link, and in the footer
Repeated next to the open-an-account button, so the offer and the risk are read together, and again in the footer.
Arabic edition
The broker's approved Arabic text, set right-to-left, with the same figure — not the IB's own translation.
Social posts
The broker's abbreviated warning in the post itself. The link leads to the full warning; it does not replace it.
Each quarter
The new figure goes into every edition and every pinned post on the same day.
One lesson from building these pages: a warning set under a portrait reads as more marketing. Gravity's legal page, which carries the full notice, is text-only by design, and the one-page site's own footer carries a warning so no reader has to follow a link to find one9.
Where a warning fails
What this means for an IB
An IB does not write a risk warning; they carry one. Ask the broker which version goes on a webpage and which in a short post, which translations are approved, and how a new figure reaches you; any rules on partners' marketing belong in the partner agreement. Where your readers are matters as much as where the broker is, and an IB writing for several countries may meet several regimes. For the page around the warning, see why an IB needs a website; for right-to-left editions, publishing in Arabic and Persian.
The warning, checked
- The broker's approved wording, unchanged, with its current figure.
- On the page: the full warning, at body-text size or larger, in its own box, visible without scrolling.
- It stands beside every account link and again in the footer.
- Social posts carry the short version in the post itself.
- Every language edition carries the broker's approved translation.
- Nothing on the page contradicts it: no "risk-free", no promised returns.
- The broker's compliance team has seen the page.
Questions
What should a forex risk warning say?
Does a forex risk warning need to appear in social media posts?
Does the risk warning have to be in Arabic or Persian?
Sources
- Notice of ESMA's Product Intervention Decisions in relation to contracts for differences and binary options (ESMA35-43-1135) — European Securities and Markets Authority
- Questions and Answers on ESMA's temporary product intervention measures on the marketing, distribution or sale of CFDs and binary options to retail clients (ESMA35-36-1262) — European Securities and Markets Authority
- Public Statement on identifying derivatives within the scope of the national product intervention measures on CFDs (ESMA35-243228190-8024) — European Securities and Markets Authority
- COBS 22.5 Restrictions on the retail marketing, distribution and sale of contracts for differences and similar speculative investments — Financial Conduct Authority (FCA Handbook)
- 20-254MR ASIC product intervention order strengthens CFD protections — Australian Securities and Investments Commission
- 26-004MR ASIC secures nearly $40 million in refunds to investors and drives change after CFD sector falls short — Australian Securities and Investments Commission
- Regulatory Guide 234: Advertising financial products and services (including credit) — Australian Securities and Investments Commission
- COB 6.16.4 — Conduct of Business Module (COB), DFSA Rulebook — Dubai Financial Services Authority
- How Gravity builds an IB website — Gravity
Terms in this article
Gravity Editorial
Written by the people who build Gravity, from what the product does and what building it taught us. Figures come from Gravity's own measurements or from the source cited beside them; nothing on these pages is trading advice. See how we write.
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