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.
| Question | European Union | United 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.
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