An FCA-regulated broker's CRM must do more than onboard clients. It should run appropriateness assessments, categorise clients as retail or professional and map them to the right leverage, store KYC and every decision in an audit trail, feed client money reconciliation, track complaints and vulnerable customers, and produce the outcome data the Consumer Duty requires. It must also be supportable under FCA outsourcing and operational resilience expectations, so check the vendor's hosting, security, exit and data-export terms.
- Appropriateness tests and client categorisation must link to leverage groups on the platform.
- Every KYC, categorisation and approval decision needs an audit trail.
- Consumer Duty requires outcome data: support, complaints, value and vulnerable customers.
- The CRM should feed daily client money (CASS) reconciliation.
- Vendor due diligence covers security, resilience, data location and exit plans.
Looking for a forex CRM? Appropriateness tests, categorisation, audit trails and reporting. Our own custom CRM and software plans start from USD 500.
A forex CRM is the system where clients register, verify their identity, deposit and get support. For an FCA-authorised broker it is also the main record of how you treated each client. This checklist covers what a UK broker's CRM should do. For the basics, read what a forex CRM is.
1. Onboarding and appropriateness
- Configurable appropriateness questionnaires for CFDs and rolling spot forex, with scoring and outcomes.
- Clear handling of clients who fail: warnings, cooling-off periods or refusal, depending on your policy.
- KYC with ID and address checks, sanctions and PEP screening, and ongoing monitoring.
- Records of every answer, document and decision, with timestamps and the user who approved them.
See KYC and AML for forex brokers.
2. Client categorisation and leverage
| Feature | Why it matters |
|---|---|
| Retail, elective professional and per se professional status | Different protections and leverage limits apply |
| Evidence for professional requests | Store the assessment and the client's written request |
| Automatic platform group mapping | Retail clients land in groups with FCA leverage limits (30:1 on major pairs, lower on other assets) |
| Periodic reviews | Reminders to review professional status |
3. Consumer Duty data
Since July 2023, the Consumer Duty requires firms to monitor outcomes for retail clients. Your CRM should give you:
- support response and resolution times,
- complaints by type, outcome and root cause,
- flags and notes for vulnerable customers,
- communication records, including risk warnings shown, and
- data on fees, costs and client outcomes for fair value reviews.
4. Payments and client money
- Deposits and withdrawals linked to trading accounts, with approval workflows.
- Withdrawals back to the original payment method where your policy requires it.
- Exports that feed daily client money reconciliation in your back office.
- No bonus or incentive features for retail clients, in line with FCA CFD rules.
5. Introducers and partners
If you work with introducers or appointed representatives, the CRM should track who introduced each client, what marketing they used and how they are paid. See IB and affiliate management.
6. Reporting and audit
- Management information for the board and compliance committee.
- Audit logs of every user action, with role-based access.
- Exports for transaction reporting and regulatory returns through reporting and BI.
7. Vendor due diligence
The FCA expects you to manage outsourcing risk and stay within impact tolerances for your important business services. Before choosing a CRM vendor, check:
| Area | Questions |
|---|---|
| Security | Encryption, multi-factor authentication, penetration testing |
| Resilience | Hosting, backups, recovery times and incident reporting |
| Data | Where data is stored, UK GDPR compliance, ownership and export |
| Exit | How you leave and move data if the contract ends |
| Access | Audit and information rights for you and the FCA |
Read our wider guide to technology due diligence for licence applications.
How we help
Our forex CRM is our own software, so it can be configured for your permissions and policies: appropriateness workflows, categorisation, audit trails and reporting. Your compliance team decides how it is set up. See our forex CRM, United Kingdom page and UK brokerage guide.
General information reviewed November 2026, not legal, tax or investment advice. Rules change; confirm your model with qualified local counsel. MetaTrader is a trademark of MetaQuotes Ltd.