# What the FCA Handbook PERG says about a UK publisher carrying paid broker links Independent and unofficial. Not affiliated with or endorsed by any broker or platform named here. Educational only: nothing here is advice, and nothing here recommends a broker or a trade. This is the markdown version of https://openbrokerapi.com/guides/section-21-and-affiliate-links, written from the same records as that page. Risk warning: CFDs and spread bets are complex instruments and come with a high risk of losing money rapidly due to leverage. You can lose money on these products, and each provider publishes its own loss figure under FCA rules. You should consider whether you understand how they work and whether you can afford to take the high risk of losing your money. Automated and API trading can amplify losses through bugs, connectivity failures and runaway orders. Only the PERG paragraphs opened on 25 Sep 2026 are used here, and each one is named. This is a reading of those paragraphs as drafted. It is not legal advice, it is not an FCA statement, and this site is not a law firm. - Last reviewed: 2026-09-25 Unverified in part: carried over from an earlier version of this site. The links below are the sources it was written from, but its statements have not been re-read at source since the date shown, so check anything you rely on. ## 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](https://www.handbook.fca.org.uk/handbook/PERG/8/12.html), 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](https://www.handbook.fca.org.uk/handbook/PERG/8/9.html), 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](https://www.handbook.fca.org.uk/handbook/PERG/8/12.html), 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](https://www.handbook.fca.org.uk/handbook/PERG/8/17.html), 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](https://openbrokerapi.com/brokers/capital-com) and [eToro](https://openbrokerapi.com/brokers/etoro), and the other fourteen publish no rule on the point either way. - [Independence and disclosures](https://openbrokerapi.com/about/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](https://openbrokerapi.com/brokers/ig), [OANDA](https://openbrokerapi.com/brokers/oanda), [Saxo](https://openbrokerapi.com/brokers/saxo), [Interactive Brokers](https://openbrokerapi.com/brokers/ibkr), [FOREX.com and City Index](https://openbrokerapi.com/brokers/forex-com-city-index), [FXCM](https://openbrokerapi.com/brokers/fxcm), [Pepperstone](https://openbrokerapi.com/brokers/pepperstone), [Axi](https://openbrokerapi.com/brokers/axi), [Dukascopy](https://openbrokerapi.com/brokers/dukascopy), [Swissquote](https://openbrokerapi.com/brokers/swissquote) and [cTrader](https://openbrokerapi.com/platforms/ctrader). - [Corrections and right of reply](https://openbrokerapi.com/corrections), if a paragraph here is read wrongly. ## Related pages - [Getting started with API trading](https://openbrokerapi.com/guides/getting-started-with-api-trading): What an API is, what you need and how to make a first call safely. - [All guides](https://openbrokerapi.com/guides): Step by step guides, each step with the page it was read on. - [Brokers](https://openbrokerapi.com/brokers): The record for each broker: access, limits, endpoints and error codes. - [Platform APIs](https://openbrokerapi.com/platforms): APIs that belong to trading software offered by many brokers. - [Error codes](https://openbrokerapi.com/errors): What each error means, and the fix where the source gives one. - [Compare two APIs](https://openbrokerapi.com/compare): The same fields from two records, side by side. - [Learn to code](https://openbrokerapi.com/learn): A learning track from a first script to a demo account call. ## Licence and how to cite The records behind this page are all rights reserved. This file is the page itself, at its own address, in another format. It is not part of the CC BY 4.0 downloads listed at https://openbrokerapi.com/data. Quote from it with a link to the page. Cite as: What the FCA Handbook PERG says about a UK publisher carrying paid broker links. Broker API Hub, https://openbrokerapi.com/guides/section-21-and-affiliate-links, newest check 2026-09-25. Where you rely on a single figure, cite the source and the checked date printed beside it as well. Where this page and a broker's own documentation differ, the documentation wins.