Client Protection & Disclosure Code

(1) This Code applies to all licensees overseen by the Neves Licensing Authority, NFSA and NGA, unless a specific exemption is set out in writing by a competent body.

(2) The Code covers, at a minimum:

1. pre-contract information and key-facts documents;
2. marketing content and promotional materials;
3. ongoing statements, notifications and updates; and
4. client communications during complaints, incidents and exit.

Licensees shall embed the following themes in their client-facing material and processes:

1. Clarity – information is written in plain, direct language appropriate for the target market.
2. Balance – benefits and opportunities are presented alongside key risks and limitations.
3. Timeliness – clients receive important information early enough to make decisions.
4. Accessibility – information is easy to find, read, download and save.

(1) For each core product or service offered to retail clients, a licensee shall prepare a concise Key-facts document (“KFD”).

(2) The KFD shall, at a minimum, set out:

1. what the product is and how it works in simple terms;
2. the main risks, including loss potential and leverage where relevant;
3. fees, spreads, commissions and other main charges;
4. who the product is designed for, and who it is not suitable for; and
5. how a client can complain or exit.

(3) The KFD shall be no longer than a reasonable number of pages for the target audience and must not be used to hide terms in fine print.

(1) Licensees shall use clear, prominent risk warnings wherever products or services present a material risk of loss, including trading, derivatives and gaming products.

(2) A risk warning shall:

1. be close to the main claim or headline, not hidden at the bottom of content;
2. use font size and contrast that are easy to read; and
3. avoid technical jargon where a simple phrase is available.

(1) Where illustrations or examples of potential returns, payouts or outcomes are used, they shall include balanced scenarios (for example favourable, neutral and unfavourable) and state clearly that they are illustrations, not promises.

(1) All marketing, promotions and online content shall be consistent with the Market Conduct & Consumer Protection Act, 2025 and with the KFD.

(2) A licensee shall not:

1. overstate likely returns or winning chances;
2. suggest that trading or gameplay is a guaranteed source of income;
3. target audiences for whom the product is clearly unsuitable.

(1) Where a licensee uses social media, affiliates or influencers to promote its offerings, it remains responsible for the content used on its behalf.

(2) The licensee shall ensure that:

1. core risk warnings are not removed or diluted;
2. any paid or sponsored content is clearly identified as such where local law requires; and
3. statements made about the licensee are accurate and not misleading.

(1) Time-limited offers, bonuses or promotions shall not be structured in a way that pressures clients into decisions they do not understand.

(2) All key conditions and restrictions (for example turnover requirements, withdrawal limits, expiry dates) shall be clearly and prominently disclosed alongside the offer.

(1) A licensee shall maintain a clear, up-to-date schedule of fees and charges, accessible at all times from its main website and client portals.

(2) The schedule shall group fees in a logical way, such as:

• account and platform fees;
• trading-related costs (spreads, commissions, swaps);
• gaming-related fees and house margins; and
• non-trading fees (for example inactivity, withdrawal, conversion).

(1) Material changes to fees or pricing practices shall be notified to existing clients in a durable medium within a reasonable time before they take effect.

(2) Notices shall explain what is changing, when it will apply, and what options clients have if they do not wish to accept the change.

(1) For trading and investment services, licensees shall provide clients with clear explanations of:

1. how orders are handled, executed or matched;
2. the role of dealing desks, liquidity partners or internalisation where relevant; and
3. how slippage, gaps and latency may affect outcomes.

(1) For gaming and wagering services, licensees shall give clients clear information on:

1. how odds, payouts or prize structures are determined;
2. whether outcomes are determined by random number generators or other mechanisms; and
3. any house margins or built-in edge.

(1) Where there is a material outage, disruption or incident affecting trading, gameplay or access to funds, licensees shall promptly post clear updates through appropriate channels, including direct client notifications where necessary.

(1) Clients shall have access to regular account statements showing, at a minimum:

1. opening and closing balances for the period;
2. cash movements, deposits and withdrawals;
3. fees and charges; and
4. trades, bets or game activity relevant to the account.

(1) Statements and confirmations shall be available in a format that clients can view, download and store for their own records.

(1) Licensees shall clearly display complaints and support channels on their websites, platforms and key documents, including email, webform or other contact routes accepted for formal complaints.

(1) Clients shall be informed of:

1. expected timelines for the licensee’s own response; and
2. how they may escalate matters to the Neves Licensing Authority, NFSA or NGA if they remain dissatisfied, in line with the Complaints, Investigations & Enforcement / Redress Act, 2025.

(1) Licensees shall present clear, simple information on how clients may close accounts or discontinue services, including:

1. any steps clients must take before closure; and
2. how remaining balances or open positions will be treated.

(1) The Authority, NFSA and NGA may use this Code when:

1. assessing licensee applications and fit-and-proper status;
2. conducting onsite and offsite supervision; and
3. considering actions under the Market Conduct & Consumer Protection Act, 2025 or the Complaints, Investigations & Enforcement / Redress Act, 2025.

(1) The Authority may update this Code from time to time, following appropriate consultation where practicable, to reflect experience, emerging practices and developments in client protection.

(1) Existing licensees shall, within the transitional period set out in a notice issued by the Authority, bring their disclosures, websites, platforms and client-facing processes into alignment with this Code.

(2) New licensees shall comply with this Code from the date they commence business, unless otherwise specified by the Authority.