The rule.
COBS 4.12A.21R prescribes the wording of the risk warning on any cryptoasset financial promotion reaching UK consumers, wherever the firm is based. No paraphrasing, no substitutes.
“Take 2 minutes to learn more” must link to the FCA’s prescribed risk summary, or a word-for-word copy on the firm’s own domain.
What it requires.
Exact wording. Verbatim — no shortening, no substituting “crypto” for “crypto-asset.”
Prominence. At the start of the promotion. Webpage: above the fold. Video: first 5 seconds. Banner ad: within the visible frame.
Linked risk summary. A clickable link to the FCA’s prescribed risk summary, or a self-hosted exact copy.
Personalisation overlay. For direct-offer promotions, an additional personalised warning is required before transacting.
Frictionless first interaction. The warning must be readable without dismissing a cookie banner, signing up, or solving a captcha.
Common violations.
“Crypto is high-risk. Only invest what you can afford to lose. Click here for more.”
Similar is not prescribed. The text is not a guideline; it is the wording.
Hero CTA “Buy BTC” visible on first paint; warning text 800 pixels below.
The user can complete the CTA without seeing the warning. Fails prominence.
Cookie consent modal covers warning until dismissed.
On the page but operationally hidden. Fails — same for a paywall or signup modal.
Mobile app navigation menu: “200x leverage · Trade now.” No prescribed risk warning on the menu surface.
Every surface promoting leverage is a financial promotion and needs the warning. The Trust Wallet finding pattern.
How to comply.
Store the prescribed wording as a single source-of-truth string in your CMS. Lint against it. Block any deviation.
Warning in the visible viewport on first paint. Test mobile (~375×667) and desktop (~1280×800).
The phrase must be a working hyperlink to the FCA risk summary or your verbatim copy. Test it in deploy CI.
Cookie banners must not overlay the risk warning — move the banner to the footer or the warning above the overlay.
Every in-app surface with a buy/trade/earn CTA — menu, push, banner, splash — needs a reusable warning component. The free ad-creative compliance scan reports whether a warning is prominent within the visible frame.
Related rules.
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The second layer, 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 assets need both.