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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.

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.

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.

• Measure the predominant size: the size used for most of the text, usually body and table text.
• Set every risk statement at that size or larger: the marketing-communication line, past-performance and currency warnings, capital-at-risk wording, risk-indicator text and key risks.
• Place risks next to benefits. Risks should not be pushed to a footnote or a separate page from the performance figures.
• Keep contrast high: dark text on a light background, never pale grey for warnings.
• Smaller text is acceptable only for non-risk labels such as column headers, chart axes and legends.

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

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:

• the fund is authorised overseas but not in the UK
• the Financial Ombudsman Service is unlikely to be able to consider complaints about the fund, its operator or depositary
• claims for losses relating to the operator and depositary are unlikely to be covered by the Financial Services Compensation Scheme
• investors should consider getting financial advice and read the prospectus

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.

• Approval before publication. UK promotions must be approved by an authorised firm, which confirms compliance before they go out.
• Record keeping. Under COBS 4.11.1R, UK firms must keep an adequate record of every financial promotion they communicate or approve: 5 years for MiFID business and 3 years for other business such as fund management.
• Ongoing monitoring. The Consumer Duty requires firms to check that communications keep producing good outcomes. A factsheet that is out of date must be corrected or withdrawn.
• EU supervision. ESMA's 2023 supervisory review of marketing communications looked at firms' internal approval processes, the involvement of control functions and consistency with legal documents.

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

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.

Related

Sources

• FCA Handbook COBS 4.5: Communicating with retail clients (non-MiFID provisions)
• FCA Handbook COBS 4.5A: Communicating with clients, including past, simulated past and future performance (MiFID provisions)
• FCA Handbook COBS 4.6: Past, simulated past and future performance
• FCA Handbook COBS 4.11: Record keeping
• FCA Handbook COBS 4.12A: Restricted mass market investments
• FCA Handbook COBS 4.15: Promotion of OFR recognised schemes
• FCA Handbook PRM 12.1: Advertisements
• FCA: Information for firms looking to offer crypto ETNs
• Commission Delegated Regulation (EU) 2019/979
• Maples Group: ESMA Guidelines for Fund Marketing Communications

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.