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UK and EU fund factsheet rules: a compliance checklist

A fund factsheet is a marketing communication. In both the UK and the EU that brings specific rules on how risks are shown, how past performance is presented and which statements must appear. This guide summarises them for fund marketing, product and compliance teams.

Last reviewed 30 October 2026 · About 8 minutes to read

Please note: this guide summarises the rules as we understand them at the date of review. It is general information, not legal or regulatory advice. Regulations and guidance change, and their application depends on each firm's circumstances, so always check the current rules and take professional advice before relying on it. See our Terms and Disclaimer.

1. Which rules apply

Which rules apply depends on where the factsheet is distributed and what the product is. A UCITS ETF marketed in both the EU and the UK has to meet both sets.

RuleApplies toWhat it means for a factsheet
FCA Consumer Duty (PRIN 2A)UK firms serving retail customersCommunications must support consumer understanding and be tested for their audience. It builds on the older Treating Customers Fairly principle.
FCA COBS 4.2All UK financial promotionsFair, clear and not misleading.
FCA COBS 4.5 and 4.5AUK communications: 4.5 for non-MiFID business with retail clients; 4.5A for MiFID business with retail and professional clientsFirm named; fair and prominent risks; risk wording at least the predominant font size.
FCA COBS 4.6UK promotions showing performanceFive complete 12-month periods, source stated, prominent warnings.
FCA COBS 4.15Overseas funds recognised in the UK (e.g. Irish UCITS)Four statements on authorisation, the Financial Ombudsman and the FSCS.
EU Regulation 2019/1156 and ESMA marketing guidelinesMarketing of UCITS and AIFs in the EUPrescribed marketing-communication wording; risks as prominent as rewards; performance rules.
Prospectus advertisement rules (EU Delegated Regulation 2019/979; UK PRM 12.1)ETPs, ETNs and other securitiesThe word "advertisement", prospectus statements and a comprehension alert for complex products.

COBS 4.5 vs 4.5A: which applies to your factsheet?

Both sections set the same core standard for a factsheet: name the firm, give a fair and prominent indication of risks, and set the risk wording at least at the predominant font size. Which one applies depends on the business the communication relates to, not on the document.

COBS 4.5COBS 4.5A
BusinessDesignated investment business that is not MiFID business, such as a UK UCITS manager or AIFM promoting its own fundsMiFID business, equivalent third-country business and optional exemption business, such as a MiFID portfolio manager or distributor
ClientsCommunications addressed to, or likely to reach, retail clientsRetail clients and professional clients
Firm name and risksCOBS 4.5.2RCOBS 4.5A.3R
Past performanceCOBS 4.6.2RCOBS 4.5A.10R (simulated past performance 4.5A.12R, future performance 4.5A.14R)

In practice: a UK fund management company promoting its funds to retail investors usually works to COBS 4.5 and 4.6. A MiFID investment firm, for example a delegated investment manager or a distributor issuing the factsheet, works to COBS 4.5A, which also covers factsheets aimed at professional investors. The performance rules are close: five years of complete 12-month periods, the source stated, and a prominent warning that past performance is not a reliable indicator of future results. If more than one firm issues or approves the factsheet, check which business each is carrying on.

2. Risk warnings and font size

No UK or EU rule sets a fixed point size for factsheets. The test is relative. FCA rules (COBS 4.5.2R and 4.5A.3R) and the ESMA guidelines both require the font size used for risk information to be at least equal to the predominant font size in the document, and the risk wording to be prominent.

A common failure is setting the disclaimers a point or two smaller than the body text. That breaches the rule even if the wording itself is correct.

3. Past performance

RequirementUK (COBS 4.6.2R)EU (ESMA guidelines)
Period coveredPreceding 5 years, or since launch if shorter10 years for funds with a KID (5 for others), or since launch
BasisComplete 12-month periodsComplete 12-month periods; current year may be added, updated quarterly
WarningProminent: figures refer to the past and past performance is not a reliable indicator of future results"Past performance does not predict future returns", placed before the figures
ProminenceNot the most prominent featureNot the main part of the communication
CurrencyState the currency and warn that returns may change with currency fluctuationsSame
Source and feesReference period and source stated; effect of fees disclosed if grossConsistent with the KID

In practice this means showing calendar-year bars or rolling 12-month returns, leaving out part-years in calendar-year charts, and thinking carefully before showing 1-month or 3-month returns in a retail document.

4. Statements that must appear

EU marketing of UCITS and AIFs

The ESMA guidelines set the standard wording:

This is a marketing communication. Please refer to the prospectus of the [fund] and to the KID before making any final investment decisions.

The factsheet should also say where the summary of investor rights can be found and state that the management company may terminate its marketing arrangements.

UK promotion of overseas funds

Under COBS 4.15.2R, a promotion of an overseas fund recognised in the UK must clearly state that:

A UK financial promotion must also be made or approved by an FCA-authorised firm, so the approving firm should be named.

ETFs

Explain that shares bought on the secondary market cannot usually be sold back directly to the fund, that investors buy and sell through a broker and may pay fees, and that they may pay more than net asset value when buying and receive less when selling.

ETPs, ETNs and other securities

Advertisements for securities with a prospectus must show the word "advertisement" prominently and say where the prospectus can be obtained. They must state that approval of the prospectus should not be understood as an endorsement of the securities, and recommend reading the prospectus before investing in order to fully understand the potential risks and rewards. For complex products they must also include the comprehension alert:

You are about to purchase a product that is not simple and may be difficult to understand.

5. Crypto ETPs and ETNs

Since 8 October 2025, UK retail investors can buy crypto ETNs that are on the FCA Official List and traded on a UK recognised investment exchange. They are classed as restricted mass market investments, so UK promotions must carry the prescribed risk warning from COBS 4.12A, prominently and in a bordered box:

Don't invest unless you're prepared to lose all the money you invest. This is a high-risk investment and you should not expect to be protected if something goes wrong.

Digital versions also need a "Take 2 mins to learn more" link to the prescribed risk summary. Incentives to invest are banned, and the distributor must run appropriateness checks and offer a cooling-off period. In the EU, crypto ETPs are securities rather than MiCA crypto-assets, so the prospectus advertisement rules and the PRIIPs KID apply.

6. Approval, records and audit trail

Factsheets are not audited by the fund's external auditor, but regulated firms must be able to show how each one was approved and what it was based on.

In practice, keep for every factsheet the final published version, who approved it and when, the source data behind each figure, the checks that were run, and any corrections made after publication.

7. The checklist

Every factsheet

Performance

Depending on product and market

Our sample UCITS ETF factsheet and sample crypto ETP factsheet show these requirements applied. For how factsheets relate to KIDs and the new UK product summaries, see Factsheet vs KID.

Sources

Important information

This guide has been prepared with care and is believed to be accurate as at 30 October 2026, but it is a general summary only and may not be complete. It is not legal, regulatory or compliance advice and must not be relied on as such. Rules, guidance and regulators' interpretations change, sometimes without notice, and we do not undertake to keep this guide up to date. Before relying on any point, check the current text of the relevant rules and take appropriate professional advice. Each firm's compliance function remains responsible for approving its own marketing communications. To the extent permitted by law, autoFactsheet accepts no liability for any loss arising from reliance on this guide; see our Terms and Disclaimer. If you spot something that is out of date, please let us know at info@autofactsheet.com.

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