The Financial Conduct Authority has published findings from a supervisory review of trading apps (neo-brokers), covering firms of different sizes and business models, to help new entrants and existing firms understand their obligations. The review highlights a mix of positive practices and areas for improvement across product governance and distribution, pricing and value, digital engagement features and controls around access to higher-risk products. The FCA surveyed 28 firms (27 responses) and conducted a more detailed review of 12 firms, noting that offerings commonly include fractional shares (17 firms), contracts for difference (8), options (7) and individual savings accounts (9), with 11 firms planning to introduce new products. It flags specific risks where apps operate via introducer models that route customers to overseas affiliates, and expects regulated firms to understand manufacturer and distributor requirements and make clear to customers when trading agreements sit with overseas entities and whether protections for assets may be reduced. Firms are also expected to define target markets at a sufficiently granular level under PRIN 2A.3 and PROD 3, assess and manage conflicts arising from revenue drivers (including FX fees, subscriptions and interest on cash balances), demonstrate fair value under PRIN 2A.4, and run robust appropriateness tests (as applicable under COBS 4.12A.28R or COBS 10/10A) for complex or high-risk products. The FCA encourages firms to take account of the findings and points readers to related FCA publications on digital engagement practices, price and value and appropriateness testing, including a research paper titled "Playing the market: a behavioural data analysis of digital engagement practices and investment outcomes" dated 11 April 2025.

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