{ "license": "https://creativecommons.org/licenses/by/4.0/", "source": "https://brokerfit.io/en/methodology/open-data", "attribution": "BrokerFit (https://brokerfit.io/en/methodology/open-data), CC BY 4.0", "slice": "custody", "schema": "https://brokerfit.io/data/schema.json#/$defs/custody", "lastVerified": "2026-09-08", "nextVerification": "2026-12-09", "records": [ { "broker_slug": "just2trade", "broker_name": "Just2Trade", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "The Company reserves the right and the Client acknowledges the Company's right to keep the Client's monetary funds and financial instruments in omnibus accounts opened with third parties on a fungible basis.", "offers_share_cfd": null, "cfd_quote": null, "insolvency_quote": "In cases specified in the Law, if the Company is unable to fulfill its obligations under these Terms and Conditions, retail Clients have a right to receive compensation from the above mentioned Fund.", "shortfall_quote": "In the event of the insolvency or any other analogous proceedings in relation to that third party, the Company may only have an unsecured claim against the third party on behalf of the Client, and the Client will be exposed to the risk that the money received by the Company from the third party is insufficient to satisfy the claims of the Client with claims in respect of the relevant account.", "entity": "J2T Services Ltd (Cyprus, CySEC CIF 281/15)", "condition": "Applies to J2T Services Ltd, the Cypriot entity licensed by CySEC under CIF 281/15, whose Terms and Conditions (revision 22.07.2026) are the document quoted below. Those terms oblige the company to have purchased securities registered in the relevant register at the client's expense, and separately permit it to hold them in omnibus accounts with third parties on a fungible basis. They contain no clause placing client securities outside the company's own estate if it fails; the only protection named is membership of the Investor Compensation Fund. Whether this entity also sells contracts for difference on shares was not established — its own documents name no equity-CFD product and no clause denying one.", "verified_at": "2026-09-08", "source_url": "https://j2t.com/files/j2t/regulatorydocs/Terms%20and%20Conditions%20for%20the%20Provision%20of%20Investment%20Services_eng.pdf" }, { "broker_slug": "interactive-brokers", "broker_name": "Interactive Brokers", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "IBIE may register your Client Assets in the name of an eligible nominee, and in such circumstances, the Client Assets will not be registered in your name. (v) Client assets may be held in an omnibus account with a third party.", "offers_share_cfd": true, "cfd_quote": "CFDs are contracts with IBIE as your counterparty, and are not traded on a regulated exchange and are not cleared or settled on a central clearing house. With respect to CFDs in shares, no CFD transaction shall confer on you any right, voting right, title or interest in any underlying product.", "insolvency_quote": "In order to show that Client Assets are not available to IBIE creditors, IBIE will ensure that its records show that Client Assets are held for Clients and that they do not belong to IBIE, sub-custodians or any other customers of IBIE.", "shortfall_quote": "Where IBIE holds Client Assets in bank account(s) or with other third parties, such Client Assets may be pooled. This means that in the event of IBIE's failure you do not have a claim against a specific sum or securities held in a specific account, and your claim may only be for a share of the total Client Assets held in that pool.", "entity": "Interactive Brokers Ireland Limited (Ireland, Central Bank of Ireland C423427)", "condition": "Applies to Interactive Brokers Ireland Limited, under the client agreement dated 24 April 2024 quoted below. The same agreement grants IBIE a right of use over client financial instruments for securities financing, on its own account or for the account of another person. Interactive Brokers LLC (US) and Interactive Brokers U.K. Limited are separate entities with their own agreements and their own custody terms; which entity onboards a reader resident outside the EEA is not answered by this document.", "verified_at": "2026-09-08", "source_url": "https://ndcdyn.interactivebrokers.com/Universal/servlet/Registration_v2.formSampleView?formdb=4750" }, { "broker_slug": "xtb", "broker_name": "XTB", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "In accordance with the FCA Rules, custody assets are held with approved eligible custodians or relevant parties in accounts specifically designated as our client asset accounts. This means that you remain at all times the 'beneficial owner' of those investments, even though a company independent of us or a nominee company may be registered as the 'legal owner'.", "offers_share_cfd": true, "cfd_quote": "We act as principal for Over the Counter Derivatives – XTB Limited deals with You on a matched principal basis.", "insolvency_quote": "In the event of XTB Limited insolvency You may make a compensation claim to the Financial Services Compensation Scheme (FSCS).", "shortfall_quote": "As your custody assets are pooled in an omnibus account with those of our other clients, you may be required to share proportionally in any shortfall.", "entity": "XTB Limited (UK, FCA FRN 522157)", "condition": "Applies to XTB Limited, the UK entity authorised by the Financial Conduct Authority (FRN 522157, company number 07227848), under its Terms of Business version 14.07.2026. That document keeps two products apart: real shares and ETFs are 'Organised Market Instruments' held under the client-asset rules, while stock CFDs are over-the-counter derivatives in which XTB Limited itself is the counterparty. Fractional shares are a further case — the terms state the whole instrument is not registered to the account, only the right to the fraction. Which XTB entity holds the contract for readers in the EU or the CIS was not established in this check.", "verified_at": "2026-09-08", "source_url": "https://www.xtb.com/en/files/xtb-uk-terms-of-business-v.-14072026.pdf" }, { "broker_slug": "exante", "broker_name": "EXANTE", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "EXT will segregate Clients' Assets from assets belonging to EXT; provided that Clients' Assets may be placed or kept in a common pool of identical assets or otherwise deposited in an omnibus clients' account.", "offers_share_cfd": null, "cfd_quote": null, "insolvency_quote": null, "shortfall_quote": "You acknowledge that your assets may be placed or kept in a common, omnibus or client account of EXT or any Delegate or are otherwise commingled with assets belonging to other customers, and that if there is an un-reconcilable shortfall in any such account, you may have to share in that shortfall.", "entity": "EXT Ltd (Cyprus, CySEC 165/12)", "condition": "Applies to EXT Ltd, the Cypriot entity licensed by CySEC under number 165/12, under Terms of Business v9.0 (07.25). This document never states in as many words that the client acquires title to the securities; what it does state is that EXT executes orders for and on behalf of the client and not as principal, and that it segregates client assets from its own while pooling them in an omnibus account. It also puts retail clients' financial instruments outside title-transfer collateral arrangements. LHCM Ltd and XHK Limited, the other entities behind the EXANTE brand, publish separate terms that were not read here, and whether this entity sells contracts for difference on shares was not established.", "verified_at": "2026-09-08", "source_url": "https://exante.eu/files/terms-business_new_ext/" }, { "broker_slug": "tickmill", "broker_name": "Tickmill", "real_shares": false, "holding_model": "none", "holding_quote": null, "offers_share_cfd": true, "cfd_quote": "It is understood that when trading in CFDs, there is no delivery or safekeeping of the Underlying Asset to which the CFD is referring to.", "insolvency_quote": "The Company is a member of the Investors Compensation Fund (ICF). So, depending on his classification, the Client may be entitled to compensation from the ICF in the event that the Company is unable to meet its obligations.", "shortfall_quote": null, "entity": "Tickmill Europe Ltd (Cyprus, CySEC CIF 278/15)", "condition": "Applies to Tickmill Europe Ltd, licensed by CySEC under CIF 278/15. No Tickmill document says outright that the company does not offer real shares; the finding rests on four things its own documents do say. Its order-execution policy scopes itself to 'all the types of Contracts for Difference offered by the Company'. The client agreement's only product appendix is the CFD trading terms. Its definition of an underlying asset lists currency pairs, metals, equity indices, forwards and commodities, and no individual shares. And every key information document on its Cyprus legal page, including the one for stocks, is a CFD document. Tickmill UK Ltd and Tickmill Ltd (Seychelles) were not examined.", "verified_at": "2026-09-08", "source_url": "https://www.tickmill.com/files/documents/legal-documents/cysec/client-agreement.pdf" }, { "broker_slug": "admirals", "broker_name": "Admirals", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "You consent to the Securities being safekept on a nominee account (including on a custodian's nominee account) along with the Securities belonging to the custodian or other clients.", "offers_share_cfd": true, "cfd_quote": "When trading CFDs you are not trading on a regulated market or exchange. You will enter directly into a contract with us in respect of the underlying financial instrument or thing on which the price of the CFD is based.", "insolvency_quote": "We are covered by the Cypriot Investor Compensation Fund. Should we be unable to meet our liabilities in respect of investment business, if you make a valid claim, you may be entitled to redress from the ICF in respect of the investments that we arrange or deal in for you.", "shortfall_quote": "You consent to the use of your Securities safekept in the interests or on your account or another client or to the pledging or encumbering of such Securities (including a set-off at the expense of the Securities).", "entity": "Admirals Europe Ltd (Cyprus, CySEC 201/13)", "condition": "Applies to Admirals Europe Ltd, licensed by CySEC under number 201/13, under its terms and conditions of 19.11.2024. One entity sells both product lines under one contract, and the split is by account type rather than by company: real shares and ETFs are the securities bought through the Invest.MT5 account, while CFDs are a separate product. The same contract has the client acknowledge that securities held with the custodian may not be distinguishable from the custodian's own. The custodian is not named anywhere in the document, and the referenced securities-trading terms and securities risk disclosure could not be retrieved.", "verified_at": "2026-09-08", "source_url": "https://admiralfiles.s3.amazonaws.com/docs/CYSEC/en/Cysec_Terms_and_Conditions_19_11_2024.pdf" }, { "broker_slug": "freedom-finance", "broker_name": "Freedom Finance", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "Normally, Custody Assets will be held in the name of an eligible nominee. If Custody Assets are held in Company name or that of a custodian, the Custody Assets may not be segregated or separately identifiable from Company Assets or those of a custodian and, in the event of a default by the Company or the custodian, may be not as well protected from any claims by the Company creditors.", "offers_share_cfd": null, "cfd_quote": null, "insolvency_quote": null, "shortfall_quote": "Investments registered or recorded in the name of a nominee will be pooled with those of one or more of the Company's other clients. In the event of an irrecoverable shortfall following any default or failure by the custodian responsible for pooled investments, the Client may not receive full entitlement and may share in that shortfall pro-rata to original share of the Assets in the pool.", "entity": "Freedom Finance Europe Ltd (Cyprus, CySEC CIF 275/15)", "condition": "Applies to Freedom Finance Europe Ltd, licensed by CySEC under CIF 275/15, under its General Terms of Business effective 01.07.2026. The same terms give the client a right to demand delivery of some or all of the portfolio held in the securities account on three business days' written notice. The nominee and the custodian are never named. Whether this entity sells contracts for difference on shares was not established: the terms of business do not contain the words 'CFD' or 'contract for difference' anywhere, and its current fee schedule prices only exchange-traded stocks, ETFs, futures and options — but neither document denies such a product outright.", "verified_at": "2026-09-08", "source_url": "https://freedom24.com/download/documents/1188/General_Terms_of_Business_01072026" }, { "broker_slug": "etoro", "broker_name": "eToro", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "Your securities will be pooled together with our other clients' securities (we call this an 'Omnibus Account') with a third party depositary in the name of eToro Europe on behalf of our clients. In such case, it may not be possible to separate your securities from those of other clients.", "offers_share_cfd": true, "cfd_quote": "We may act as principal or on a matched principal basis when providing you with the CFD Trading Services. This means we will be the counterparty to your trades.", "insolvency_quote": "If we or our third-party nominee becomes insolvent, your securities may not be immediately identifiable by separate certificates, physical documents, or equivalent electronic entries on the register. Instead, any claim will be against the Omnibus Account, and therefore more time might be needed for us to identify which securities are yours, and which belong to a different client.", "shortfall_quote": "If there is an unreconciled shortfall caused by the default of a custodian, you may share proportionately in that shortfall.", "entity": "eToro (Europe) Limited (Cyprus, CySEC 109/10)", "condition": "Applies to eToro (Europe) Limited, licensed by CySEC under number 109/10, under the terms published 12.08.2026. Here whether you get a real share depends on the trade rather than on the instrument: the terms execute unleveraged buy orders in securities as securities, but execute leveraged buys, all short positions, trades by users from certain countries and trades on certain exchanges as CFDs instead, at eToro’s own discretion. In both cases the terms state that eToro may act as principal or on a matched principal basis and is the counterparty to your trades. The third-party depositary is never named.", "verified_at": "2026-09-08", "source_url": "https://www.etoro.com/wp-content/uploads/2026/03/etoro_EU_TnC_Publication_2026-08-12_Clean-1.pdf" }, { "broker_slug": "degiro", "broker_name": "DEGIRO", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "DEGIRO uses SPVs to hold Money and other Financial Instruments for the Client. The SPVs are passive entities established as foundations (stichtingen) under the laws of the Netherlands. By using the SPVs, clients' positions in Financial Instruments are segregated from the capital of DEGIRO and will remain available for the clients of DEGIRO in the unlikely event DEGIRO becomes insolvent.", "offers_share_cfd": null, "cfd_quote": null, "insolvency_quote": "DEGIRO holds Financial Instruments for you in such a way that they cannot be accessed by creditors of DEGIRO, even if DEGIRO would be declared bankrupt.", "shortfall_quote": "If there is a deficit in a certain currency or in a certain Financial Instrument, which DEGIRO and SPV holds for the account and risk of the clients of DEGIRO, then DEGIRO will be entitled to divide this deficit over all clients of DEGIRO for whose account such currency or Financial Instrument is or should be held, pro rata to the total position of such currency of Financial Instrument that should be held for each of them.", "entity": "flatexDEGIRO Bank SE, acting through its Dutch branch, trading as DEGIRO (Germany, BaFin and Bundesbank; branch supervised by AFM and DNB)", "condition": "Applies to flatexDEGIRO Bank SE through its Dutch branch, under the client agreement and investment services information published for Ireland, document version 20220830 — which still names the company flatexDEGIRO Bank AG, the form it held before converting to an SE; the broker's own help centre now writes SE, and that is the name used here. The custody arrangement is the one thing that sets this broker apart on this page: client instruments are held not by the broker but by separate Dutch foundations with no members or shareholders, which is what makes them bankruptcy-remote from DEGIRO. Within those vehicles the instruments are still held in omnibus accounts, pooled with other clients. Whether the broker sells contracts for difference on shares was not established: the words do not appear in the client agreement, the investment services information or the instrument catalogue, but no document denies such a product outright.", "verified_at": "2026-09-08", "source_url": "https://www.degiro.ie/data/pdf/ie/Client_Agreement_Investment_Services_Terms_and_Conditions.pdf" }, { "broker_slug": "trading-212", "broker_name": "Trading 212", "real_shares": true, "holding_model": "omnibus-pooled", "holding_quote": "Whenever your Investments are registered in the name of a Nominee Company nominated by us, that Nominee Company will hold them on trust for you. This means that you are the beneficial owner of the Investments. Your Investments will be registered in the same name as those of other clients (pooled together with other clients’ Investments in an omnibus co-mingled custody account, like with like).", "offers_share_cfd": true, "cfd_quote": "Buying CFDs on a stock does not make you a shareholder in the respective company. You shall not have voting rights or liquidation rights. When trading with CFDs, you and we explicitly agree that neither of us shall physically acquire the base instrument purchased by the CFD.", "insolvency_quote": "If we or the Nominee Company used by us were to become insolvent, there may be delays in identifying individual assets, and possibly an increased risk of loss if there should be a shortfall because additional time may be needed to identify the assets held for specific clients.", "shortfall_quote": "In the event of an unreconciled shortfall caused by the default of a custodian, you may share proportionately in that shortfall.", "entity": "Trading 212 EU GmbH (Germany, BaFin 10109603)", "condition": "Applies to Trading 212 EU GmbH, the entity Trading 212's own help centre names as \"the sole provider of the custody services\" after migrating client assets out of Trading 212 Markets Ltd. The nominee and omnibus wording quoted below is from the Invest terms issued by Trading 212 Markets Ltd (Cyprus, CySEC 398/21) and predates that migration; the German entity's own custody terms were not obtained in this check, so treat the mechanism as described rather than as re-confirmed for the new custodian. CFDs are a separate contract under which no underlying instrument changes hands on either side. The nominee company is never named, and the CFD terms do not state in as many words who acts as counterparty. Trading 212 also runs a UK entity under FCA supervision, which these documents do not cover.", "verified_at": "2026-09-08", "source_url": "https://www.trading212.com/legal-documentation/cy/invest/Invest-Terms_EN.pdf" } ] }