Why disclosure structure matters

A cost page is useful only when a reader can connect each number to a product, account, instrument, legal entity, currency and time. A prominent minimum spread can be accurate yet still omit commission, financing and conditions that materially affect the result.

This analysis examines the anatomy of a disclosure. The cited broker pages are examples of document structure, not evidence that one provider is cheaper.

Layer 1: identity and scope

The page should identify the legal entity or country context to which it applies. It should also distinguish CFDs, spread betting, futures or other products where their cost models differ. A global brand page without an entity or regional scope should not be assumed to describe every client.

Layer 2: account and platform

Accounts can combine costs differently. A standard account may include a markup in the spread, while a commission account may present a lower raw spread plus a separate charge. Platform choice can also affect the quoted commission or available account.

Pepperstone’s UK cost page, for example, separates Standard, Razor and spread-betting structures and explains that commission can vary by account and platform. This is useful disclosure architecture, but the current figures must still be checked for the reader’s exact entity and setup.

Layer 3: spread statistics

A disclosure should label a spread as minimum, typical, target, average or current. Minimum means the lowest stated value under specified conditions; it is not a forecast. An average is meaningful only with a measurement period and method.

IG’s UK product-details material distinguishes minimum and average spread fields for selected markets. That distinction helps a reader avoid treating a lower bound as a normal outcome.

Layer 4: commission units

Commission should state whether it is per side or round trip, per lot or per unit, fixed or percentage-based, and whether a minimum applies. The trade size and account currency are essential.

A sound comparison converts every commission to the same basis. If one page says “per side” and another says “round trip”, copying the two numbers into a table without adjustment creates a false comparison.

Layer 5: holding costs

The disclosure should explain when overnight financing or swap applies, the daily cut-off, the benchmark or rate source, the broker adjustment, weekend treatment and where current rates can be found. Cash and forward-style products may treat financing differently.

IG’s UK help material describes overnight funding as a separate daily adjustment for relevant cash CFD and spread-bet positions. OANDA’s UK charges page separates financing fees from spreads and other account costs. These examples show why the holding period belongs in any cost comparison.

Layer 6: conversion and non-trading fees

Currency conversion, inactivity, withdrawals, deposits, data and optional order features may sit on different pages. OANDA’s UK charges page, for example, identifies financing, inactivity and possible bank charges around deposits or withdrawals. A broker saying it charges no withdrawal fee does not mean every bank in the payment chain charges nothing.

Layer 7: effective date and evidence

Every cost record needs an access date and, where available, an effective date or document version. Live or variable values should be labelled as such. A screenshot without its entity, URL and date is weak evidence.

A normalized extraction template

  • Brand and legal entity
  • Jurisdiction and client type
  • Product, instrument and account
  • Platform and account currency
  • Spread label and measurement basis
  • Commission unit, side and minimum
  • Financing rule and holding period
  • Conversion and non-trading fees
  • Source URL, effective date and access date
  • Missing, conditional or conflicting information

Three states for every field

“Disclosed” means the source states the value or rule for the defined context. “Not documented” means the research did not find enough evidence. “Not applicable” means the cost does not apply under the stated conditions. These states should never be collapsed into zero.

What a responsible comparison says

A comparison can say that two disclosures use different account models or that one source does not document a field. It should not call a broker “cheapest” unless equivalent contexts, live or representative data and all material costs have been aligned. Even then, costs can vary with trading behaviour and market conditions.

The FCA’s 2025 review of CFD price and value reinforces the importance of considering spreads, commissions, overnight funding and disclosure clarity together. The conclusion is methodological: cost research requires a full, dated record, not a single promotional number.