The trading platform still opens. The logo has not changed. Your balance is where you left it. Then an email says your account will move to another company unless you accept new terms, take action before a deadline or continue using the service.
That is not a routine marketing update. The company named in your agreement can determine which regulator record matters, which rules cover the account, where client money is held, who answers an old complaint and what happens if the firm fails.
Short answer: a broker can sometimes change its legal structure, transfer business or invite you to move to another group entity. Those are different legal mechanisms. Do not accept the message at face value. Save the current agreement, identify the proposed company and verify the transfer terms before the deadline.
This guide shows how to investigate the notice. It does not decide whether a transfer is legally valid for your account. That depends on the contract, country, product and client classification.
First, work out which change is actually happening
Emails often use soft phrases such as “service update” or “new terms” even when the contractual change is more important. Put the notice into one of these four groups before you compare protections.
| What the notice describes | What may be changing | Evidence to request | Main question |
|---|---|---|---|
| New legal status | The firm changes its legal structure | Old and new company details, regulator notice or authorisation, amended contract | Is this still the same authorised business for your agreement? |
| Business transfer | Another firm becomes the service provider | Transfer notice, receiving firm’s terms, consent method and effective date | Who becomes responsible for the balance, positions and older complaints? |
| Move to a group company | You open or migrate to an affiliate in another jurisdiction | New account agreement, licence record, country eligibility and opt-out terms | Which protections and remedies disappear or change? |
| Terms or brand update | The counterparty may stay the same | Versioned terms and a summary of amendments | Does the legal name in the agreement actually change? |
The UK FCA’s guidance shows why this distinction matters. A change of legal status may require a new authorisation application or a regulatory notification, depending on the structure. The FCA also says ongoing customer contracts must be amended or replaced to reflect the new entity. A separate FCA page on business transfers says the receiving firm generally needs to supply its terms and obtain evidence of client consent for the business covered by that guidance.
Use the documents in the right order
The broker’s homepage is weak evidence. It is written for the brand and may show licences held by several group companies. Start with the documents linked to your account.
- Your current client agreement. Record the full company name, registration number, regulator, governing law and version date.
- The migration or change notice. Find the proposed company, effective date, consent method, opt-out procedure and treatment of open positions.
- The proposed agreement. Compare the entity, product permissions, client classification, money wording, fees, termination clause and complaint route.
- Your account record. Save statements, trade history, payment beneficiaries and the entity shown in the platform footer or account profile.
- The official register. Search the exact company, then match the licence number, approved website, status and relevant permissions.
If the notice names only a brand, ask for the complete legal name before continuing. The FCA specifically tells CFD customers to use the terms and conditions to identify the contracting entity and its country of incorporation. Our legal-entity verification guide shows how to match that name to an official record.
A real contract shows what useful transfer wording looks like
Contract wording differs by firm and jurisdiction, so a concrete example is more useful than a generic promise. XTB MENA Limited’s General Terms and Conditions, version 15 April 2026, contain a client-money transfer section for a transfer of accounts or business.
Clauses 9.8 to 9.10 state that the firm can transfer client money in that situation, describe at least 10 business days’ written notice, and say the client can terminate the agreement before the transfer and ask for the money to be returned. The document also describes a post-transfer notice explaining the receiving person’s protection arrangements and any compensation scheme.
Why this example matters: it gives the customer dates, an exit route and specific information to expect. It does not prove that every XTB account uses those terms, that another broker must use the same timetable or that a transfer is automatically suitable.
Find the equivalent clause in your own agreement. Search for assignment, transfer, novation, amendment, termination and client money. Our broker agreement clause guide explains what each section can change.
One brand can publish different documents for different entities
Pepperstone’s official legal pages provide a simple worked example. Its UK page publishes documents for Pepperstone Limited. Its EEA page identifies Pepperstone EU Limited. The design and brand are familiar, but the legal-document sets are entity-specific.
This is not a review or recommendation of Pepperstone. It demonstrates the document-routing problem: a group licence page cannot tell you which agreement applies to your account. The answer must come from the onboarding route and the document you are asked to accept.
For a jurisdiction-level comparison, read FCA, CySEC or offshore: what changes under a different legal entity. It separates operating safeguards from complaint and compensation routes.
What can change even when the platform looks identical?
| Checkpoint | Old account | Proposed account | Why you should record it |
|---|---|---|---|
| Contracting company | Legal name and number | Legal name and number | Identifies the counterparty |
| Regulatory permission | Entity, licence and product | Entity, licence and product | Group authorisation does not automatically transfer |
| Client classification | Retail or professional | Retail or professional | Can change available safeguards |
| Open positions | Prices, margin, swaps and history | Transfer, closure or replacement terms | Creates a record before the effective date |
| Client money | Holder and payment beneficiary | Holder and payment beneficiary | Shows who receives or returns funds |
| Complaints | Firm and external route | Firm and external route | Old and new disputes may follow different routes |
| Failure compensation | Scheme and eligibility wording | Scheme and eligibility wording | A limit is not a guarantee of eligibility |
| Fees and execution | Versioned schedule and policy | Versioned schedule and policy | Group companies can use different terms |
Read the notice according to what it asks you to do
Check the treatment of open positions and older complaints
A migration notice should not leave you guessing about positions that are already open. Ask whether they will remain open, close, be transferred or be replaced. Request written treatment of entry prices, swaps, margin, stop orders, trade history and account balances.
Also ask which company will handle a complaint about conduct that happened before the effective date. The FCA’s legal-status guidance says a Deed Poll declaration is intended to prevent firms from leaving existing customer complaint obligations behind when changing legal entity. That is a UK regulatory example, not a global rule. Your notice and applicable framework still need to answer the question for your account.
If a withdrawal is already delayed, do not let the migration email erase the timeline. Preserve the old entity’s documents and follow the withdrawal dispute evidence route. You can also use the Broker Complaint Route Finder to identify a stored country and entity route.
Pressure to move offshore deserves a separate check
ESMA has warned CFD providers against encouraging EU retail clients to move to intra-group firms in third countries as a way of avoiding product-intervention measures. It has also warned about pressure to request professional-client status.
That warning does not mean every third-country company is fraudulent. It means higher leverage or fewer restrictions should not distract you from the legal consequence of changing counterparty. Verify the new company as a separate firm and compare the remedy available after a dispute.
- the notice omits the proposed legal name or effective date;
- the new company cannot be matched to the relevant official register;
- the firm will not provide the proposed agreement and version date;
- open positions, balances or older complaints are not addressed;
- the payment beneficiary changes without independent confirmation;
- you are offered higher leverage but no clear explanation of lost protections;
- the message creates urgency while withholding an opt-out or termination route.
A pause is not a finding of fraud. It is a response to missing evidence.
Seven checks to complete before the deadline
- Download the current agreement, the proposed agreement and the migration notice.
- Write the old and new legal names, company numbers, regulators and licence numbers side by side.
- Search the new company on the official register and confirm the website and relevant permission.
- Save statements, balances, trade history and current payment details before the effective date.
- Record what happens to open positions, client money, withdrawals and unresolved complaints.
- Compare client classification, fees, execution terms, complaint route and any failure-compensation wording.
- Save the firm’s written answer and the date you checked every official source.
The free Broker Evidence Comparison Tool can place stored country and entity records side by side. Use it as an organiser, then confirm every material detail in your agreement and the official register.
What the evidence cannot prove
- An authorised group company does not prove that it is the company in your agreement.
- A transfer clause does not by itself prove that every legal and contractual requirement has been met.
- A regulator record does not guarantee withdrawals, service quality or recovery after a dispute.
- A compensation limit does not mean your client type, product or loss will qualify.
- A familiar platform, domain or logo does not keep old protections attached to a new counterparty.
The practical rule
Do not ask only whether the broker is changing its legal entity. Ask which company will owe you the service after the effective date, what document makes that change, what happens if you decline and which route remains available if something goes wrong.
The logo may stay where it is. Your evidence file should not.
Official sources and verification log
- FCA: Client agreements for transferring investment business. New terms and evidence of consent in the transfer scenarios covered by the guidance. Checked 1 September 2026.
- FCA: Change of legal status. Authorisation or notification, contract treatment and existing complaints. Checked 1 September 2026.
- FCA: Contract for differences. Contracting-entity and overseas-entity context. Checked 1 September 2026.
- FCA Handbook: COBS 8A.1 Client agreements. Written agreement and pre-contract information for applicable business. Checked 1 September 2026.
- EUR-Lex: Delegated Regulation (EU) 2017/565. Client information, agreement and material-change framework for applicable investment services. Checked 1 September 2026.
- ESMA: Warning to CFD providers. Professional-client pressure and intra-group third-country routing. Checked 1 September 2026.
- ESMA Q&A 1978. A specific EU CFD example involving changes to terms and existing positions. Checked 1 September 2026.
- Pepperstone UK legal documents and Pepperstone EEA legal documents. Entity-specific document example only, not an endorsement. Checked 1 September 2026.
- XTB MENA Limited General Terms and Conditions, version 15 April 2026. Clauses 9.8 to 9.10 are used as a current transfer-clause example only, not an endorsement or universal rule. Checked 1 September 2026.
Educational information only. This article does not provide legal or investment advice, rate a broker’s safety or guarantee that a regulator, ombudsman or compensation arrangement will accept a claim.