Trading 212 UK Limited · DRN-5944825

The complaint Mr M has complained that Trading 212 UK Limited shouldn’t have allowed him to open a contract for difference (‘CFD’) position when the underlying asset was suspended. He wasn’t able to sell the position and was facing a financial loss of around £30. To put the matter right he wants compensation for the loss plus interest and £500 for the stress and inconvenience caused. What happened Mr M had been trading with T212 since January 2023. On 7 February 2025 Mr M opened a CFD position in MutliMetaVerse Holdings Ltd (‘MMVVF‘) but shortly after he found that he couldn’t close the position. He learned the underlying asset had had no prices for months but said T212 continued to display the CFD as tradeable with bid/ask prices, would accept pending orders and allow new customers to open positions. Mr M raised a complaint with T212 on 14 March 2025 about the lack of transparency, misleading platform behaviour, unfair treatment of clients and failure to acknowledge its execution responsibility. T212 responded on 17 April 2025 not upholding the complaint. It said; • Any instrument could be suspended if no price quote had been received for five minutes or more. • MMVVF was downlisted on 13 January 2025. T212 wasn’t a financial adviser and any decisions were Mr M’s own. He traded at his own risk. It referred to its Risk Disclosure Notice. • The instrument wasn’t tradeable due to lack of quotes. It wasn’t delisted. • It could only offer closure at $0 per unit. • It couldn’t agree T212 was responsible for executing the trade or failed to inform Mr M of the risks inherent in CFD trading. It hadn’t failed to treat him fairly or act with due skill and care. Unhappy with the outcome Mr M brought his complaint to the Financial Ombudsman Service. Our investigator who considered the complaint didn’t think T212 needed to do anything more. She said; • T212’s Disclosure Notice outlined the liquidity risk in CFD trading. • The account was execution only and it was for Mr M to decide if a trade was right for him. • T212 had confirmed the screenshots that Mr M showed the instrument was tradeable were the option to set a take profit or stop loss order and not a buy option. • Trading was set to close only, so it wasn’t misleading to new customers that the instrument was available to buy.

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T212 had nothing further to add but Mr M didn’t agree with the investigator. He said; • His complaint hadn’t been addressed namely, T212 continued to display a suspended asset as fully tradeable which gave a misleading impression the market was functioning as it should. • He provided screenshots that contradicted the conclusions reached by the investigator which hadn’t been acknowledged or investigated. The platform didn’t reflect a suspended asset. • The investigator had relied on the general Risk Disclosure Notice rather than the specific facts of the case and generic disclaimer couldn’t excuse misleading platform behaviour. • The investigator contradicted herself, bearing in mind the evidence he had provided. As the complaint remained unresolved it has been passed to me for a decision in my role as ombudsman. Mr M provided some further points for my consideration but concluded that he wanted me to assess whether T212 had complied with the regulator’s Principles and rules, determine whether displaying buy/sell prices on a frozen asset breached T212’s duty to treat its customers fairly and communicate clearly and consider an appropriate remedy for the financial loss and the distress, inconvenience and loss of confidence caused by the misleading interface. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. After doing so, I’ve reached the same conclusions as the investigator and broadly for the same reasons. I’ll explain why. I should first explain the Financial Ombudsman Service provides an informal complaint handling service and this is reflected in the way I’ve approached the complaint. It’s part of my role to identify and concentrate on the core issues I need to address in order to reach a fair outcome. This means I won’t necessarily mention everything Mr M has brought to my attention and I’ve expressed some of his concerns in my own words. But I will comment on everything that makes a difference to the outcome of the complaint. And our approach is inquisitorial, not adversarial, and the purpose of the decision is to provide a report of my determination as to what is fair and reasonable in the circumstances, not a point by point response to the submissions made by the parties to the complaint. And I assure the parties that I have carefully considered everything, even if I have not specifically commented on it. Mr M has asked me to determine whether T212 has breached the Financial Conduct Authority’s (‘FCA’) Principles and rules, in particular; Principle 6: Customers’ interests – A firm must pay due regard to the interests of its customers and treat them fairly. Principle 7: Communications with clients – A firm must pay due regard to the information needs of its clients, and communicate information to them in a way which is clear, fair and not misleading. COBS 2.1.1R: A firm must act honestly, fairly and professionally in accordance with the best interest of its client.

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The FCA’s Principles have a wide application and I have therefore considered all of Mr M’s points with the Principles and rules in mind as a relevant consideration throughout my decision. Mr M has provided detailed submissions for my consideration and I thank him for the time and effort he has spent in bringing his complaint. As briefly detailed in the background Mr M has raised many concerns about whether T212 complied with the rules and regulations when its platform showed active buy/sell buttons, bid/ask prices and an active opening order interface. He said there were no warning of suspension, delisting or liquidity and no notice before or after he opened the trade. Plus, months after suspension the platform still displayed live pricing, a full trading interface, functioning take profit/stop loss options and the ability to attempt to open further positions. But in my view the crux of the complaint is whether T212 should have allowed Mr M to have opened a CFD for MMVVF in the first instance. I say this because while I am aware Mr M has evident concerns about what was shown on T212’s platform, but those arose after the event – the event being Mr M opening the CFD – and whether Mr M should have been given any warnings in advance of the opening bet. I say this because whatever happened after the opening bet – increased in the lack of liquidity etc – wouldn’t have impacted on Mr M’s execution only decision to trade. What transpired couldn’t have been known by any party at the time of the opening trade. MMVVF were downlisted from the Nasdaq on 10 January 2025 and Mr M’s opening bet took place on 7 February 2025. I asked T212 why Mr M was allowed to trade when volume in the underlying instrument had significantly reduced. T212 said at the time of the trade the underlying instrument was still tradeable albeit with lower volumes. I’ve looked at the chart for MMVVF for when Mr M traded and the daily volume traded did significantly decrease from the date of delisting to date of Mr M’s trade. But clearly, they were still tradeable and T212 was receiving price feeds. And even if the stock itself loses its main exchange listing – Nasdaq in this case – and moves to the OTC market, T212 can continue to offer it as long as there is an available price feed and liquidity which was T212’s conclusion, albeit at a reduced notional value. And in response to the lower liquidity T212 significantly reduced the notional value with a maximum of 660 shares per position (Mr M’s trade quantity was 420), equivalent to $143.75 notional value as per the average opening price of Mr M. This is because T212 had to manage risk given the lack of liquidity and this shift in notional value wasn’t unusual. So, I don’t agree with Mr M that T212 should not have offered him the facility to open his trade as clearly there was sufficient liquidity at the time for it to do so. But T212 wasn’t responsible for what happened after that. I say this because Mr M’s account was an execution only one and the sole responsibility for any investment decisions were his own. He couldn’t expect any guidance or notification from T212 – that wasn’t its role – as detailed in T212’s Risk Disclosure Notice; ‘10.1. Execution Only - You trade entirely at your own risk Our service is "execution only", meaning we will only carry out your trading instructions. We shall not offer you any advice or recommendation regarding the suitability of any investments with us, and nothing we send or tell you should be interpreted as such. We do not provide investment, tax or trading advice. Our service is "execution only", meaning we will not advise you on any transaction, nor will we

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monitor your trading decisions to determine if they are appropriate for you or to help you avoid losses…’ T212’s role was to act as an intermediary and counterparty – trades aren’t conducted on an exchange or market – that provided liquidity and trade execution for its customers. T212 did provide that service when Mr M opened his position, but circumstances changed when liquidity further reduced. The Risk Disclosure Notice also warns of liquidity risk; ‘10.7. Liquidity Risk Under certain circumstances, it may not be possible to close a part of or a whole position at the current price or at all. We are not obligated to provide quotes for any CFD at any time, and we do not guarantee the continuous availability of quotations or trading for any CFD. We may at our sole discretion cease quoting CFDs and/or cease entering new CFD or Shares transactions at any time based on lack of market data, halts or suspensions or errors or illiquidity or volatility in the market for the Underlying product, or our own risk or profit parameters, technical errors, communication problems, market or political or economic or governmental events, Acts of God or Nature, or for other reasons.’ Mr M disagrees with the reliance on the Risk Disclosure Notice and says it only addresses the possibility that a market may become illiquid or quotations may cease. He says it doesn’t permit T212 to continue to display a suspended asset as fully tradeable with live/bid ask prices and an active buy button. But the key point here is that when Mr M opened his trade – irrespective of the downlisting to OTC about which T212 wasn’t obliged to inform Mr M – there was sufficient liquidity available so what displayed on the interface after that wouldn’t have changed Mr M’s current position. That being said, it was inevitable the options available on the interface would change as circumstances changed. On 21 August 2025 Mr M provided a screenshot (I don’t know the date of the screenshot) to show that for MMVVF it said; ‘You can place market orders after the instrument receives a new price. Pending orders are still accepted.’ This suggests that this time T212 wasn’t receiving new price feed that allowed for a new price – it told us that in August 2025 there was still the option to set a take profit or stop loss – but it was allowing for pending orders in the expectation that a new price might happen. However, this didn’t turn out to be the case. On 10 September 2025 T212 provided a screenshot (again, date of the screenshot unknown) to show that if the buy option was clicked the following would show ‘Trading Limited’ and; ‘The instrument is set to close-only. You can close or reduce existing positions, but new orders are not allowed.’ Mr M provided a further update in that he checked the T212 platform in November 2025 and found the display was; ‘Trading Limited – close only’ He said this message didn’t appear during the period covered by his complaint but during that time it showed buy/sell buttons and this evidenced T212 had since modified its interface so was effectively acknowledging the original version was misleading. But I disagree with

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Mr M. The above changes in the interface are what I would expect to see when it became clearer – as time went on – that trading wouldn’t be possible when circumstances changed and liquidity dried up. It wasn’t T212’s role to have informed Mr M of MMVVF’s downlisting from the Nasdaq to OTC. It was for Mr M to have established that information and to have made himself aware of the potential impact of that – OTC stocks generally offering less liquidity and more volatility – before he proceeded with his opening bet. MMVVF had a very small market capitalisation of $1.85m but despite that the fact that T212 was able to offer Mr M the facility for him to have opened the trade shows it was satisfied it was receiving sufficient price feed at the time. But those circumstances changed which ultimately led to the ‘close only’ status of the trade. Clearly Mr M has been distressed by the change in the interface between his opening trade and now and would have liked more – and for him – more accurate information during the intervening period. But that doesn’t detract from the fact that Mr M had already opened his position by that time. And whatever information Mr M saw about the possibility to trade didn’t take away from the outcome that a lack of liquidity meant Mr M couldn’t close his trade. In March 2025 T212 offered to close Mr M’s trade at zero and understandably that is an unsatisfactory outcome for Mr M as he has said this would cause him a financial loss and ongoing restriction of his funds on the platform. But quite simply the price feed/liquidity isn’t available for T212 to allow Mr M to close his position any other way. I appreciate what has happened has caused Mr M to have lost confidence in the platform and his inability to trade and information provided to him on T212’s platform has caused him considerable distress. But I don’t agree T212 has done anything wrong or not complied with the regulator’s rules in that it would have made a difference to the outcome. T212 allowed him to open his trade when there was a market available to support that trade but circumstances changed and Mr M can’t close his position as he would like. But overall, it was Mr M’s decision to open a position where the underlying instrument had very recently downlisted to the OTC market where illiquidity and volatility were a real possibility. And the underlying instrument had a very small market capitalisation which again could indicate a lack of liquidity. But it was for Mr M to have established that information in his assessment of whether to open a CFD. In conclusion, I don’t uphold Mr M’s complaint. I appreciate he will be disappointed with the outcome – it’s clear he feels strongly about it – but I hope I have been able to explain how and why I have reached the decision that I have. My final decision For the reasons given, I don’t uphold Mr M’s complaint about Trading 212 UK Limited. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr M to accept or reject my decision before 23 April 2026. Catherine Langley Ombudsman

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