Crypto risk warnings: EU against UK.

MiCA Articles 6(5) and 66(3) against COBS 4.12A.11R and the UK risk summary: who must warn, what wording is fixed, and where the warning must appear.

The UK prescribes the words; the EU prescribes the substance. A UK cryptoasset promotion carries a fixed sentence and links a fixed risk summary. Under MiCA the white paper carries the value-loss statements, the service provider warns its clients, and the marketing must stay consistent with both. A single pan-European creative rarely satisfies both regimes as written.

QuestionEuropean UnionUnited Kingdom
The warning in the promotion itself

UK: exact prescribed words in every promotion. EU: a duty on the provider to warn of the risks, with no fixed wording in MiCA itself.

Article 66(3)

Warn of the risks. Link the white paper.

COBS 4.12A.11R(1)(d)

The exact UK crypto risk warning.

The longer risk statement

UK: a prescribed two-minute risk summary. EU: the white paper's statements that the asset may lose its value in part or in full, may be illiquid and is not covered by compensation schemes.

Article 6(5)

The warnings every white paper carries.

COBS 4 Annex 1R, section 8

The two-minute crypto risk summary.

No price promises

EU: no future-value assertions in the white paper, and marketing must stay consistent with it. UK: Principle 7 — communications that are clear, fair and not misleading.

Article 6(4)

No price predictions in the white paper.

Article 7(1)(b)

Fair, clear and not misleading.

COBS 4.1.7DG

Registered is not 'FCA approved'.

Readable, in the reader's language

UK guidance names WCAG and a second language where recipients may not read English well. MiCA's language rules sit in the white paper provisions, which this library does not yet carry as a record.

No equivalent record.

COBS 4.12A.37G · 4.12A.41G

A warning nobody can read is not a warning.

Every cell is a rule record with its primary source and the date it was read (4 November 2026). All records: MiCA rule records · FCA rule records.

General, sourced information for marketing teams — not legal advice. Where a campaign runs in both markets, check it against both columns.

Know before a regulator does.

Paste a URL or your copy — the full verdict lands in seconds. Free, no signup.