Appropriateness before the first transaction.

COBS 4.12A.28R, the fourth condition, and COBS 10: assess appropriateness when a crypto order responds to a direct-offer promotion. Registered firms included.

United Kingdom FCA COBS 4.12A.28R · COBS 10.1.2R

The rule.

FCA Handbook, COBS (as amended by the Cryptoasset Financial Promotions Instrument 2023, FCA 2023/27) · COBS 4.12A.28R · COBS 10.1.2R

“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.

Violation pattern · quiz with the answers shown

Appropriateness questions with the correct option highlighted

An assessment that cannot be failed does not assess anything.

Violation pattern · skipped for app users

Web flow assesses; the app's 'quick buy' does not

Every order that responds to the promotion is in scope.

Non-compliant vs compliant.

Non-compliant · example written by NorthPoint

“Skip the quiz — tap 'I already know crypto'.”

Compliant · example written by NorthPoint

“Before your first purchase: a short assessment of your understanding of cryptoasset risks, based on COBS 10 Annex 4G.”

Related rules.

Source.

InstrumentFCA Handbook, COBS (as amended by the Cryptoasset Financial Promotions Instrument 2023, FCA 2023/27)
ProvisionCOBS 4.12A.28R · COBS 10.1.2R
Primary sourcehttps://www.handbook.fca.org.uk/instrument/2023/FCA_2023_27.pdf
Official texthttps://www.handbook.fca.org.uk/handbook/COBS/4/
Read fromFCA 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.

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