The rule.
The FCA Handbook COBS 4.12A.21R prescribes a specific wording for the risk warning on any cryptoasset financial promotion communicated to UK consumers. The wording is mandatory; firms cannot paraphrase, summarise, or substitute their own version.
The link “Take 2 minutes to learn more” must point to the FCA’s prescribed risk summary, hosted at a specific URL or replicated word-for-word at the firm’s own domain.
What it requires.
Five operational obligations.
Exact wording. The warning text must be reproduced verbatim. No paraphrasing, no shortening, no substituting “crypto” for “crypto-asset.”
Prominence. The warning must be prominently displayed at the start of the financial promotion. For a webpage, that means above the fold. For a video, in the first 5 seconds. For a banner ad, within the visible frame.
Linked risk summary. The “Take 2 minutes to learn more” phrase must be a clickable link to the FCA’s prescribed risk summary content. Firms may host the summary themselves provided it matches the prescribed text exactly.
Personalisation overlay. Beyond the prescribed warning, for direct-offer promotions, an additional personalised risk warning is required before the consumer can transact.
Frictionless first interaction. A consumer must be able to read the warning without dismissing a cookie banner, completing a sign-up, or solving a captcha.
Common violations.
“Crypto is high-risk. Only invest what you can afford to lose. Click here for more.”
Substantially similar but not the prescribed wording. Fails. The FCA is explicit that the prescribed text is not a guideline; it is the wording.
Hero CTA “Buy BTC” visible on first paint; warning text 800 pixels below.
Warning is present but not prominent. The user can complete the CTA without ever seeing the warning. Fails prominence.
Cookie consent modal covers warning until dismissed.
The warning is technically on the page but operationally hidden. Fails frictionless-first-interaction. Equally a problem if a paywall or signup modal blocks the warning.
Mobile app navigation menu: “200x leverage · Trade now.” No prescribed risk warning on the menu surface.
Leverage promotion is a financial promotion. Every surface that promotes it needs the prescribed warning. The Trust Wallet finding pattern.
How to comply.
Treat the prescribed wording as immutable. Store it as a single source-of-truth string in your CMS or component library. Lint against it. Block any deviation.
For every UK-facing landing page, place the warning in the visible viewport on first paint. Standard mobile viewport: ~375×667. Desktop: ~1280×800. Test both.
“Take 2 minutes to learn more” must be a working hyperlink to the FCA risk summary or your verbatim copy. Test the link in deploy CI.
Cookie banners must not overlay the risk warning. Either move the cookie banner to the footer (where most jurisdictions actually require it) or move the risk warning above the cookie banner’s overlay.
Every in-app surface that promotes a cryptoasset — navigation menu, push notification, banner, splash screen — counts as a financial promotion. Build a reusable warning component and place it on every surface that has a buy/trade/earn CTA.
Related rules.
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The second layer. After the prescribed warning, a personalised warning is required before transaction.
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First-time investors cannot transact within 24 hours of the direct-offer promotion.
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The EU version. MiCA requires prominence; the FCA prescribes the wording. UK-and-EU-facing assets need both.