Article 15, the introducers exemption, at PERG 8.12.11
Article 15 covers a financial promotion made with a view to introducing the recipient to an authorised or exempt person. PERG 8.12.11 sets three conditions. The introducer is not a close relative or a group company of that person. The introducer does not receive, in the paragraph’s own words:
And the introducer has not been asked for advice, or declines to give it and recommends an authorised person instead.
Read plainly, the second condition is the load bearing one for a publisher. The recipient is the reader. A commission paid by a broker is a financial reward for making the introduction, and it comes from the broker rather than from the reader, so on the condition as drafted a paid affiliate link does not sit inside article 15. That would leave only two ways a paid link works: the reader pays for the introduction instead of the broker, or the promotion is not this site’s promotion at all because an authorised firm approved it.
PERG 8.12.11A and 8.12.11B, effective 15 Jul 2026, exclude article 15 for introductions to credit broking, operating an electronic lending system, relevant consumer credit on regulated deferred payment agreements, and controlled claims management. None of those carve outs touches a CFD, FX or spread bet introduction, so none of them changes the reading above either way. Source: FCA Handbook, PERG 8.12, page last updated 15 Jul 2026, read 25 Sep 2026.
The January 2026 approver changes, PERG 8.9.1A and 8.9.1B
PERG 8.9 was amended on 19 Jan 2026 and carries that date as its last updated date. Two paragraphs matter to the second of the two routes above.
PERG 8.9.1A: an authorised person approving a financial promotion under section 21(2A) must be a permitted approver for that promotion, or fall within an approver permission exemption. An approval is therefore not something any authorised firm can simply give.
PERG 8.9.1B: the person principally responsible for the substantive content is the preparer. Minor presentational help does not make someone a preparer, and a compliance review does not make the approver the preparer. Read plainly, that cuts both ways for a publisher. It means a firm reviewing this site’s wording does not thereby become the author of it, and it means that where this site writes the substance, this site is the preparer whoever else touched the page afterwards. Source: FCA Handbook, PERG 8.9, last updated 19 Jan 2026, read 25 Sep 2026.
Article 20, the journalism exemption, PERG 8.12.25 to 8.12.27
Article 20 is the exemption a publisher reaches for first, and the principal purpose test is what it turns on. PERG 8.12.25 requires the communication to be in a newspaper, journal, magazine or other periodical publication, a regularly updated news or information service, or a broadcast, and requires that the principal purpose of the publication or service, taken as a whole, is not to advise on or lead or enable persons to buy or sell securities or relevant investments.
PERG 8.12.26 requires disclosure of a financial interest where the promotion directly identifies a person, in relation to shares and in relation to claims management. PERG 8.12.27 gives exceptions where the publisher has proper systems and procedures, or operates under an established code.
Read plainly, the principal purpose test is about what the publication is for, judged as a whole, not about how a single page is worded. A reference site whose purpose is documenting how broker APIs behave is not obviously a service for leading readers into buying investments. Adding paid links whose purpose is to move readers into broker accounts moves the publication towards the thing the test excludes, and how far is a judgement on the whole publication that this page cannot settle. Source: FCA Handbook, PERG 8.12, read 25 Sep 2026.
Article 28B, PERG 8.17.12, noted and set aside
Noted only so it is not later mistaken for a route. PERG 8.17.12 covers article 28B, which does contemplate a fee paid introduction subject to disclosure of fees and of group relationships. It is confined to qualifying credit, that is mortgage credit, so it does not apply to a CFD, FX or spread bet introduction. Source: FCA Handbook, PERG 8.17, last updated 26 Jun 2026, read 25 Sep 2026.
What else was opened, and what it did not give
PERG 8.13, last updated 1 Oct 2018; PERG 8.14, last updated 16 Sep 2026; PERG 8.15, last updated 1 Apr 2019; PERG 8.17, last updated 26 Jun 2026; and PERG 8.21, last updated 16 Sep 2026. All were opened on 25 Sep 2026 and none of them provides a route for a paid broker introduction by a UK publisher.
Where this bites on this site
- What broker partner programmes publish. The reason this page exists: only two of the sixteen programmes read publish any rule about altering creative, Capital.com and eToro, and the other fourteen publish no rule on the point either way.
- Independence and disclosures and for brokers state how this site may make money, and the model states the constraint every line of it is drawn around.
- The broker pages the programmes belong to: IG, OANDA, Saxo, Interactive Brokers, FOREX.com and City Index, FXCM, Pepperstone, Axi, Dukascopy, Swissquote and cTrader.
- Corrections and right of reply, if a paragraph here is read wrongly.