The rule.
“A registered person must establish, implement and maintain adequate policies and procedures”
Verbatim extract, read on 4 November 2026 from the source below. Everything else on this page is NorthPoint’s plain-English reading.
What it requires.
- COBS 4 applies to the registered person as it applies to an authorised person communicating a cryptoasset promotion; references to a firm include the registered person, and references to a client include anyone the promotion is, or is likely to be, communicated to.
- The firm establishes, implements and maintains adequate policies and procedures to make sure its promotions comply.
Who it applies to.
Registered persons communicating financial promotions relating to qualifying cryptoassets in reliance on Article 73ZA of the Financial Promotion Order.
Common violations in marketing copy.
Growth team ships UK social posts directly from a scheduling tool
No policy or procedure stands between the copy and the audience.
COBS is for authorised firms; we are only registered.
COBS 4.1.7CR applies the chapter to registered persons relying on Article 73ZA.
Non-compliant vs compliant.
“We're MLR-registered, so the FCA promotion rules don't apply to our ads.”
“UK promotions follow our financial-promotions procedure: draft, compliance review against COBS 4, sign-off, record.”
Related rules.
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FPO Article 73ZA · United Kingdom
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COBS 4.1.7DG · United Kingdom
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COBS 4.12A.11R(1)(d) · United Kingdom
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COBS 4.10.3G(8) · 4.10.9AR(4) · United Kingdom
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UK cryptoasset financial promotions (FSMA s21, the FPO and FCA COBS).
Source.
| Instrument | FCA Handbook, COBS (as amended by the Cryptoasset Financial Promotions Instrument 2023, FCA 2023/27) |
|---|---|
| Provision | COBS 4.1.7CR |
| Primary source | https://www.handbook.fca.org.uk/instrument/2023/FCA_2023_27.pdf |
| Official text | https://www.handbook.fca.org.uk/handbook/COBS/4/ |
| Read from | FCA 2023/27 as made (in force 8 October 2023), read from the FCA Handbook instrument PDF; the consolidated Handbook page is a script-rendered app the build session could not read |
| Checked |
This page is general, sourced information for marketing teams, not legal advice. The examples are written by NorthPoint to illustrate the rule; for a binding view on your own promotion, retain qualified counsel in the jurisdiction concerned.