The rule.
“is aware, or ought reasonably to be aware, that an application or order is in response to the direct offer financial promotion”
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.
- The fourth condition brings in the COBS 10 appropriateness assessment for qualifying cryptoassets (COBS 10.1.2R(1)(d)).
- COBS 10.2.9G and COBS 10 Annex 4G list the knowledge areas a firm should consider asking about for cryptoassets.
Who it applies to.
The firm, or the person who will transact in a qualifying cryptoasset, where it is aware or ought reasonably to be aware the order responds to a direct-offer promotion. COBS 10.1.2R(3) applies the chapter to registered persons.
Common violations in marketing copy.
Appropriateness questions with the correct option highlighted
An assessment that cannot be failed does not assess anything.
Web flow assesses; the app's 'quick buy' does not
Every order that responds to the promotion is in scope.
Non-compliant vs compliant.
“Skip the quiz — tap 'I already know crypto'.”
“Before your first purchase: a short assessment of your understanding of cryptoasset risks, based on COBS 10 Annex 4G.”
Related rules.
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COBS 4.12A.21R · United Kingdom
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COBS 4 Annex 5R · COBS 4.12A.25G · United Kingdom
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COBS 4.12A.11R(1)(d) · United Kingdom
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COBS 4.12A.7R · 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 4.12A.28R · COBS 10.1.2R |
| 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.