FCA and CySEC are the two Tier-1 regulators that show up most often across the brokers we've researched -- 33 of the 139 brokers in our dataset hold both licences at once, usually through separate UK and EU entities under the same brand. They're often treated as interchangeable "proper regulation," but they differ in ways that matter if you're actually choosing between two entities of the same broker, or deciding whether a broker's EU-only or UK-only credential is enough for you.
An FCA-authorised firm's eligible retail clients are covered by the Financial Services Compensation Scheme (FSCS) up to £85,000 per person if the firm fails. A CySEC-licensed firm's eligible retail clients are covered by the Investor Compensation Fund (ICF) up to €20,000 per person instead. Both are real, statutory schemes with a hard cap -- neither is marketing language -- but they're denominated in different currencies, set at very different levels, and each applies only to the specific entity licensed by that regulator, never to an unrelated sister brand that merely shares a brand name.
Since Brexit, an FCA licence covers UK clients only -- it no longer carries automatic EU passporting. A CySEC licence, by contrast, lets a Cyprus Investment Firm passport its services across the entire EU/EEA under MiFID II with that one licence, without needing a separate authorisation in every member state. That's why a broker serving both UK and EU clients typically runs two separately-licensed, separately-capitalised entities rather than one licence covering both regions.
Both regulators apply similar ESMA-style retail leverage caps -- typically 30:1 on major currency pairs, down to 2:1 on crypto CFDs -- since the UK retained these rules after Brexit rather than diverging from them. Where they differ more is conduct: the FCA's Consumer Duty rules require firms to actively deliver good outcomes for retail customers, not merely avoid harming them, while CySEC-licensed firms follow MiFID II's conduct-of-business rules instead. In practice, this doesn't translate into a large difference in how much leverage a retail client is offered, but it is a distinct additional obligation on the FCA side.
Whichever entity your own account is actually held with -- not the brand's overall reputation. A UK resident's compensation protection comes from the FCA entity and the FSCS; an EU resident's comes from the CySEC entity and the ICF. If a broker holds both licences, confirm in writing exactly which legal entity your account sits under, then check that entity's specific licence number against the corresponding regulator's own register -- not the brand's general claim to be "FCA and CySEC regulated."
Of the 139 brokers in our research set, 95 hold a CySEC licence, 53 hold an FCA licence, and 33 hold both at once -- typically via separate UK and EU entities rather than one licence covering both regions. 24 of the 139 hold neither as a primary credential, though many of those still hold another Tier-1 or offshore licence elsewhere in our dataset. Holding both is common among larger, more established brokers, but it never means a single compensation scheme covers every client -- each entity's scheme only ever covers its own entity's clients.
Is CySEC regulation as good as FCA regulation?
Different, not simply better or worse: CySEC covers eligible clients up to €20,000 under the ICF and carries EU-wide MiFID II passporting, while FCA covers up to £85,000 under the FSCS but applies only to UK clients post-Brexit. Which one offers more relevant protection for you depends on where you live and which entity you're actually signed up with.
If a broker has both FCA and CySEC entities, which one protects me?
Whichever entity you actually opened your account with -- not the brand as a whole. Confirm in writing from the broker exactly which legal entity holds your account, then check that entity's specific licence number against the corresponding regulator's own register.
How many brokers hold both an FCA and a CySEC licence?
33 of the 139 brokers in our research set hold both at once, typically through separate UK and EU entities under one brand -- see the full breakdown above.
See all regulation pages.