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CySEC vs FCA: which actually protects you

Ask this in any trading forum and you get a debate about reputations. The two rulebooks can instead be read side by side, and most of the debate collapses on contact: the rules that bind a broker day to day are the same rules. What survives is one real difference — the compensation scheme behind the licence — and one question neither regulator settles for you: which entity your account is actually opened with.

Same by rule

Leverage caps, the 50% margin close-out, negative balance protection. CySEC adopted ESMA’s measures outright; the FCA wrote its own permanent rules to the same percentages.

Different by rule

What you recover if the firm fails: up to £85,000 from the FSCS against the ICF’s lower of 90% of the claim and €20,000 — different amounts, different currencies, different shares of the loss.

Decided by neither

Which entity your account is opened with. A group can hold both licences and open most non-UK, non-EU accounts on a third company that holds neither.

The leverage caps, side by side

Asset class FCA CySEC
Major currency pairs 30:1 30:1
Minor pairs, gold, major indices 20:1 20:1
Other commodities, minor indices 10:1 10:1
Individual equities 5:1 5:1
Cryptocurrencies 2:1 2:1

FCA PS19/18 — COBS 22.5.11R — read 2026-08-05

CySEC Policy Statement PS-04-2019 — read 2026-08-05

Tier for tier, the two columns are the same figures — and not by coincidence. CySEC’s policy statement adopts ESMA’s tiers as permanent national measures; the FCA wrote its own rule, stated as minimum margin percentages, and arrived at the same ratios. Half the folk debate about these two regulators is an argument about leverage limits that are the same limits.

One divergence sits inside the FCA’s top tier: the same policy statement places CFDs on certain government bonds at 30:1, where ESMA’s measure had them at 5:1. It affects bond CFDs only; every row above is unchanged.

The 2:1 cryptocurrency tier is the FCA rule as written in the 2019 instrument. Whether retail cryptocurrency CFDs remain available in the UK at all is a separate question this page does not establish.

Close-out and negative balance: same trigger, same floor

The wording differs — the FCA measures net equity against the margin requirement, CySEC counts the funds in the account plus unrealised profits against half the initial margin protection — but the trigger does not: at half the required margin, the firm must start closing positions. And in both jurisdictions losses stop at the account by rule, not by the broker’s goodwill.

Margin close-out — FCA

The firm must close a retail client’s open positions when the account’s net equity falls below 50% of the margin required to maintain them.

FCA PS19/18 — COBS 22.5.13R — read 2026-08-05

Margin close-out — CySEC

Positions must be closed, on terms most favourable to the client, when funds in the account plus unrealised profit fall to 50% of the initial margin required for the open positions.

CySEC Policy Statement PS-04-2019 — read 2026-08-05

Negative balance protection — FCA

Required. Losses cannot exceed the funds in the account.

FCA Handbook -- COBS 22.5.17R — read 2026-08-06

Negative balance protection — CySEC

Required. Losses cannot exceed the funds in the account.

CySEC Policy Statement PS-04-2019 — read 2026-08-05

Compensation: the real difference

If an FCA firm fails

Up to £85,000 per eligible person, per firm, for firms that failed on or after 1 April 2019 (FSCS).

FSCS — what we cover — read 2026-08-02

If a CySEC firm fails

Up to €20,000 per covered client, and never more than 90% of the claim (Investor Compensation Fund). Professional clients are not covered.

CySEC — Investor Compensation Fund — read 2026-08-05

The shape differs as much as the size. The FSCS covers the claim itself, up to its ceiling. The ICF pays the lower of 90% of the claim and €20,000 — so a covered claim comes back a tenth short even when it is well under the ceiling, and the cap binds in full once a claim passes roughly €22,000, since 90% of that already reaches €20,000. Professional clients are outside the ICF entirely.

The two ceilings are in different currencies and this page does not convert them: the exchange rate that would matter is the one on the day a firm fails, which is not knowable now. The figures above are what each scheme itself states, with the source and the date it was read.

The registers

Both regulators run a free, public register. Search the legal entity named in your client agreement — not the brand on the website.

Financial Conduct Authority

United Kingdom

Open the FCA register

FCA Financial Services Register — read 2026-08-02

Cyprus Securities and Exchange Commission

Cyprus (EU)

Open the CySEC register

CySEC register of Cypriot investment firms — read 2026-08-05

The entity on your account decides

Comparing the two rulebooks flatters the question, because for many readers neither applies. Broker groups are structured by jurisdiction: a UK company for UK clients, a Cypriot one for the EU, and an offshore company — in Seychelles, Vanuatu, Belize or the British Virgin Islands — for much of the rest of the world. The website may name both licences and both are real. The client agreement names one company, and only that company’s regulator, caps and compensation scheme are yours.

So the productive form of “CySEC or FCA?” is not which brand to prefer but which entity a given broker would open your account on. Establishing that takes about two minutes against a public register — here is the check — and which authorities each broker names is on its broker page.

What this comparison cannot tell you

Whether any particular firm is well run. Both regimes are a floor, not a rating: authorised firms fail under both, which is why the compensation schemes exist at all. The full set of jurisdictions — including the offshore ones these same groups actually use — is on the regulation comparison.

Questions

Is CySEC safer than the FCA?
Not in the way the question assumes. The rules that bind a broker day to day — leverage caps, the 50% margin close-out, negative balance protection — say the same thing in both rulebooks, because both made the ESMA intervention permanent in national rules. The difference that survives comparison is what happens if the firm fails: the FSCS covers up to £85,000 per eligible person per firm, while Cyprus’s ICF pays the lower of 90% of the covered claim and €20,000. And neither figure applies at all unless your account sits on the entity that holds the licence.
Is a CySEC licence a real licence?
Yes. CySEC is an EU regulator with a searchable public register, and it adopted ESMA’s leverage tiers, margin close-out and negative balance protection as permanent national measures. The criticism it attracts is mostly about structure rather than rulebook: many groups hold a Cypriot licence for EU clients and open everyone else’s account on an offshore entity the licence does not cover.
How much compensation do I get if an FCA or CySEC broker goes bust?
Under the FSCS, up to £85,000 per eligible person per firm, for firms that failed on or after 1 April 2019. Under Cyprus’s Investor Compensation Fund, the lower of 90% of your cumulative covered claims and €20,000 — so even a claim below the ceiling comes back a tenth short, and professional clients are excluded entirely. The two ceilings are in different currencies, and we do not convert them: the rate that matters is the one on the day a firm fails, which is not knowable now.
Do FCA and CySEC brokers offer different leverage?
No. Both cap retail leverage tier for tier, from 30:1 on major currency pairs down to 2:1 on cryptocurrencies as the rules were written. The one divergence in the FCA’s version affects CFDs on certain government bonds, which it places at 30:1 where ESMA’s measure had 5:1. A broker advertising leverage in the hundreds under either brand is opening that account on a different entity, in a different jurisdiction, where neither rulebook applies.

Sources