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Contract reading

What BROKSTOCK legally published, but does not want you to read

Every clause below is published by BROKSTOCK itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: BROKSTOCK SA (Pty) Ltd

hidden feesole discretionwithdrawalsprofit voidingstale documentcomplaint windowdeemed acceptancemarketing gapunilateral amendmentassignment

BROKSTOCK can keep 10% of any money you withdraw within 30 days of paying it in. Closing the account inside 90 days costs R1 000. Neither fee appears on the deposits and withdrawals page, which shows 0% commission on withdrawals. The agreement also lets BROKSTOCK cancel profit it suspects came from abusive trading, while your losses from the same trades stand.

Back to BROKSTOCK

Contract risk

Money at risk
6.5/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
21
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
52
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
6

How the 21 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical6
Warning14
Notice1

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

4 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

Critical10%Fee you were not shown. Jump to the clause this comes from.A 10% fee on money you withdraw within 30 daysCritical3 working daysWithdrawal limit. Jump to the clause this comes from.Withdrawals can be reversed, restricted or refusedCritical5 working daysTime to complain. Jump to the clause this comes from.Five business days to object or the trade standsCritical2Profit at risk. Jump to the clause this comes from.Any trade closed inside two minutes can be cancelled

What the documents say

21 clauses worth knowing about, worst first, each quoted from BROKSTOCK's own files

01

Take your money out less than 30 days after paying it in and BROKSTOCK can keep 10% of it. Clause 16.21 calls this an Early Withdrawal Fee. The deposits and withdrawals page shows 0% commission on withdrawals and never mentions it.

Why this matters

R10 000 withdrawn on day 20 comes back as R9 000. Nothing in clause 16.21 asks whether you did anything wrong, only how fast you moved your money.

Exhibit 1CriticalRarely seen10%

Early Withdrawal Fee will be charged in amount of 10% on any funds withdrawn within 30 days of deposit
Clause 16.21 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.38
Downloaded from the broker's site on Open the reference
Our own capture of brokstock.co.za, taken on Aug 23, 2026The claim, on Opening lines of the Deposits and withdrawals page, above a withdrawal panel showing 0% commissionVisit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must give a retail client the costs and charges of a service before they trade, in one place. BROKSTOCK shows 0% commission on its withdrawals page and puts the 10% fee in clause 16.21 of a 59 page agreement.

BROKSTOCK is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Withdrawal within 30 days of depositBROKSTOCK charges 10% of the amount you withdraw.16.21
Account closed within 90 days of openingBROKSTOCK charges R1 000 to close the account.16.21
  • Same clause as Exhibit 2One clause holds both exit charges, so leaving early can cost a percentage and a flat fee.
  • Worse together with Exhibit 4The fee sits on top of a withdrawal BROKSTOCK can also reverse or refuse.
02

BROKSTOCK can place your uninvested money with its partners, integrated brokers and liquidity providers under clauses 15.9 and 15.16. Clause 15.6 accepts that a third party holding your money may have a security interest, lien or right of set off over it.

In plain words

Liquidity providers are outside banks and brokers.

Why this matters

If that institution fails, clause 15.2 says BROKSTOCK accepts no responsibility for the loss. Clause 15.8 leaves you with an unsecured claim against a third party you never picked.

Exhibit 15CriticalRarely seen

The Company is authorised to deposit client funds with existing company’s partners, integrated brokers, and any future similar partners for the purpose of providing additional earning capabilities to its clients.
Clause 15.9 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.33
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must keep retail client money segregated and belong to a statutory compensation scheme that pays eligible clients if the firm fails. BROKSTOCK promises segregation in clause 15.1 and names no compensation scheme anywhere in the agreement.

BROKSTOCK is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

03

BROKSTOCK promises to process a withdrawal within three business days in clause 16.8. Clause 16.17 then lets it push the payment back into your trading account if it is not satisfied with your documents. Clause 12.2.6 lets it stop you withdrawing anything at all.

Why this matters

Your money can sit in the account while BROKSTOCK decides, and no clause puts a deadline on that decision. Once a termination notice is out, clause 23.7.4 lets it refuse your withdrawal instruction outright.

Exhibit 4CriticalHarder than usual3 working days

The Company reserves the right if it is not satisfied with any documentation provided by the Client, to reverse the withdrawal transaction and deposit the amount back to the Client 's Trading Account.
Clause 16.17 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.37
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA hold client money under rules that require it to be returned promptly once it is due, with any hold recorded and explained. Clause 23.8.5 lets BROKSTOCK keep back whatever its own absolute discretion considers appropriate for future liabilities.

BROKSTOCK is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

04

BROKSTOCK can cancel your profit, your trading benefits and any bonus if it suspects what it calls Abusive Trading. Clause 12.2.8 adds that your losses from the same trades cannot be reversed. Suspicion is the trigger, not proof.

Why this matters

The definition covers arbitrage, lag trading, use of server latency and "hunting of trading benefits". It also says it is not limited to that list. A winning week can be undone while a losing one stands.

Exhibit 6CriticalHarder than usual

Cancel or reverse any profits and/or trading benefits and/or bonus gained through Abusive Trading and/or were cancelled by the Company and/or Liquidity Provider, and losses of the Client resulting from the mentioned above circumstances cannot be reversed.
Clause 12.2.8 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.30
Downloaded from the broker's site on Open the reference
  • Worse together with Exhibit 7One clause cancels profit from suspected abuse, the other cancels any trade closed inside two minutes.
05

You get five business days to object to how a trade was executed. Miss that and clause 10.14 makes the transaction valid and binding on you. Clause 13.2 does the same to account confirmations.

Why this matters

The clock starts when the trade closes, not when you notice the problem. Miss it and BROKSTOCK's own confirmation is deemed conclusive.

Exhibit 10CriticalHarder than usual5 working days

The Client may submit to the Company by electronic mail (e-mail) or in writing or by hand, his objection to the execution or the non-execution or the mode of execution of a Transaction and/or Order concluded on his behalf within five (5) Business Days from the conclusion of the Transaction. Otherwise, the Transaction shall be considered valid and binding for the Client;
Clause 10.14 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.24
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK)

Firms licensed by the FCA must let a retail client take a complaint to an independent ombudsman for at least six months after the firm's final answer. BROKSTOCK's own complaints page allows six months to reach the FAIS Ombud, but clause 10.14 closes an objection to a trade after five business days.

BROKSTOCK is not licensed by this regulator, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 11A five day objection window is harder to meet when the complaints route the contract points to names another company.

Profit can be cancelled while losses stay

Clause 12.2.8 lets BROKSTOCK cancel profits, trading benefits and bonuses gained through what it calls Abusive Trading, and says losses from those same trades cannot be reversed. Suspicion is enough to trigger it. Clause 10.24 separately allows any trade closed within two minutes to be cancelled.

Profit at risk2 clauses flagged

Closing a position within two minutes of opening it makes it a Scalping Trade under clause 2.1.47. Clause 10.24 bans those trades and lets BROKSTOCK cancel any of them.

Why this matters

A fast, profitable exit can be undone after the fact. Volatile minutes are exactly when a quick exit makes sense, and that is where this rule bites.

Exhibit 7CriticalHarder than usual2

The Client is prohibited from performing Scalping Trades. The Company reserves the right to cancel any trades that have been closed within the two (2) minute limit, and has the right to act according to the specific clause of this Agreement.
Clause 10.24 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.26
Downloaded from the broker's site on Open the reference

If your bank reverses a payment for any reason, BROKSTOCK reverses the deposit and can reverse any other transaction made after that date. Clause 16.18 accepts this may leave your account with a negative balance.

Why this matters

Trades you opened and closed after that deposit can be undone, however long ago. Clause 16.18 puts no time limit on how far forward the unwinding reaches.

Exhibit 8WarningHarder than usual

In the event that any amount received by the Client is reversed by the bank account provider at any time and for any reason, the Company will immediately reverse the affected deposit from the Client's Trading Account and reserves the right to reverse any other type of transactions effected after the date of the affected deposit.
Clause 16.18 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.38
Downloaded from the broker's site on Open the reference

The pages that sell the account promise no fees

"No additional fees" appears twice on the BROKSTOCK Packages page, and "BROKSTOCK does not charge any fees for deposits" appears on the deposits page. The agreement behind both carries a 2% administration fee, a 50 ZAR dormancy fee and a R1 000 closure fee. It also reserves a Payment Processing Fee on any deposit method.

In plain words

Dormancy means an account left unused.

Page against contract2 clauses flagged

"No additional fees" appears twice on the BROKSTOCK Packages page. The agreement behind it carries a 2% administration fee on uninvested funds, a 50 ZAR monthly fee on inactive accounts and a R1 000 account closure fee.

Why this matters

You pick a Package on the promise that a level costs nothing extra. Three separate charges in the agreement can still reach the same balance.

Exhibit 13WarningHarder than usual

the Company has the right and will apply a service administration fee of up to 2% when the client uninvested funds are held through any Liquidity Provider
Clause 15.14 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.34
Downloaded from the broker's site on Open the reference
Our own capture of brokstock.co.za, taken on Aug 23, 2026The claim, on Packages page, under the heading Manage Your Package AdvantageVisit this page on the broker's siteDownload the full size image file
  • Worse together with Exhibit 9The dormancy fee is one of the charges the page says do not exist.

"BROKSTOCK does not charge any fees for deposits" sits on the deposits and withdrawals page. The same page charges 1% on bank card top ups. Clause 16.16 lets BROKSTOCK add a Payment Processing Fee to any deposit method and amend it later.

Why this matters

Clause 16.12 puts every payment, transfer and processing charge on you, and lets BROKSTOCK debit your account for it. Free deposits are not what the contract says.

Exhibit 14WarningHarder than usual1%

The Company reserves the right, at its sole discretion, to apply Payment Processing Fee as a reasonable and transparent platform service fee covering the integration, maintenance, and processing of deposits.
Clause 16.16 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.37
Downloaded from the broker's site on Open the reference
Our own capture of brokstock.co.za, taken on Aug 23, 2026The claim, on Deposits and withdrawals page, notes under EFT TransactionThis capture shows the page the quotation was taken from. The words themselves are not marked in it, so please read the quotation above as the evidence.Visit this page on the broker's siteDownload the full size image file

Three charges that are not on the fees page

A 10% Early Withdrawal Fee applies to money you take out within 30 days of paying it in, under clause 16.21 of the BROKSTOCK service agreement. The same clause charges R1 000 to close an account inside 90 days, and clause 15.14 adds up to 2% on uninvested funds held with a liquidity provider. The deposits and withdrawals page shows 0% commission on withdrawals.

Cost disclosure2 clauses flagged

Closing your account within 90 days of opening it costs R1 000 under clause 16.21. BROKSTOCK sets the charge to discourage what it calls Transitioning of Funds, money in and straight back out.

Why this matters

Decide within three months that this is not for you, and leaving costs R1 000. That is ten times the R100 minimum deposit BROKSTOCK accepts through Capitec Pay.

Exhibit 2WarningHarder than usual$1000

Account Closure Fee will be charged in amount of R1 000 in cases where the Trading Account is closed within 90 days of opening.
Clause 16.21 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.39
Downloaded from the broker's site on Open the reference

BROKSTOCK can take a service administration fee of up to 2% when your uninvested money is held through a liquidity provider. Clause 15.14 says the fee does not change the interest rate you were quoted.

Why this matters

The Packages page sells interest on exactly these uninvested funds and promises no additional fees. Clause 15.14 does not say what the 2% is charged on, or how often.

Exhibit 3WarningHarder than usual2%

Client also acknowledges that the Company has the right and will apply a service administration fee of up to 2% when the client uninvested funds are held through any Liquidity Provider. This fee is intended to cover operational and administrative costs incurred in maintaining such arrangements and will not affect the terms, rate, or amount of interest payments.
Clause 15.14 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.34
Downloaded from the broker's site on Open the reference
  • Same clause as Exhibit 13This is the fee the Packages page says does not exist.

Every withdrawal is a decision BROKSTOCK can undo

Three business days is the commitment BROKSTOCK gives itself to process a withdrawal in clause 16.8. Clause 16.17 then lets it push the payment back into your account if it is unhappy with your documents, with no deadline on that review. On termination, clause 23.8.5 lets it hold back whatever its own absolute discretion judges appropriate.

Exit conditions1 clause flagged

Clause 15.7 says BROKSTOCK has no lien over your money and no right of set off. Clause 18.1 gives it a general lien on all funds it holds for you until your obligations are met. Clause 19.3 adds set off across your accounts.

Why this matters

Which clause wins is not stated anywhere. A lien lets BROKSTOCK keep hold of your balance until it agrees you owe nothing.

Exhibit 5WarningRarely seen

The Company does not have any security interest or lien over the clients' financial instruments or funds or any right to set-off clients' funds or financial instruments.
Clause 15.7 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.33
Downloaded from the broker's site on Open the reference

Terms, spreads and leverage can move under you

Five business days of written notice lets BROKSTOCK change any term of your agreement, under clauses 22.6 and 22.7. Spreads can be adjusted with no notice at all under clause 10.22. Staying past the effective date counts as your acceptance, and clause 22.10 makes checking for updates your job.

What can change3 clauses flagged

BROKSTOCK can change any term of the agreement for any reason, on five business days written notice, under clauses 22.6 and 22.7. Staying past the effective date counts as accepting the change. Spreads can move with no notice at all.

Why this matters

Checking for updates is your job under clause 22.10. The file BROKSTOCK's legal page labels 10 December 2025 says "Last updated: August 2026" on its own cover.

Exhibit 17WarningHarder than usual5 working days

As long as the Client is able to end the Agreement without charge, the Company may change any of the terms of the Agreement for any reason not listed under the specific clause of this Agreement.
Clause 22.6 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.43
Downloaded from the broker's site on Open the reference

Bots, algorithms and any other automated means of placing trades are banned, and clause 10.17 requires all your trading to be manual. Clause 8.1.1 adds any software applying artificial intelligence analysis, unless BROKSTOCK consents in writing.

Why this matters

Breaking either rule is an event of default. BROKSTOCK can then cancel your profits under clause 12.2.8 while your losses stay where they are.

Exhibit 18WarningRarely seen

The Client is prohibited from using any automated systems, including bots, algorithms, or other electronic means, for the purpose of executing trades on their Trading Account. All trading activity must be conducted manually by the Client to ensure compliance with this Agreement.
Clause 10.17 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.25
Downloaded from the broker's site on Open the reference

Retail clients get negative balance protection under clause 10.20, so you cannot lose more than the money in your account. Clause 10.21 then says your other positions and funds with BROKSTOCK can be used to cover a negative balance.

In plain words

Negative balance protection is a limit that stops you owing more than you put in. Without it, one fast market move can leave you owing the broker money on top of your deposit.

Why this matters

One clause caps your loss at the account, the next reaches your other money. The same clause ends by putting the loss on BROKSTOCK, so what you actually have depends on which sentence is applied.

Exhibit 19WarningHarder than usual

The Company shall provide the Retail Client with Negative Balance protection so that the Client shall not lose more than the total sum invested for trading CFDs and there can be no residual loss or obligation to provide additional funds beyond those in the Client’s Trading Account.
Clause 10.20 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.26
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), ESMA (EU)

Firms licensed by the FCA and firms under ESMA rules must give retail CFD clients negative balance protection on a per account basis. Clause 10.20 matches that, and clause 10.21 then allows other positions or funds to cover the shortfall.

BROKSTOCK is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Five business days to challenge a trade

Clause 10.14 of the BROKSTOCK agreement gives you five business days to object to how a trade was executed, after which the transaction is valid and binding. Clause 13.2 treats an unchallenged confirmation as conclusive. The complaints page the agreement points you to is written in another company's name.

Complaint deadlines2 clauses flagged

Clause 29.3 sends you to BROKSTOCK's complaints page. That page is written for BCS Markets SA (Pty) Ltd and asks you to email complaints@bcsmarkets.co.za, while clause 29.1 gives complaints@brokstock.co.za.

Why this matters

Two company names and two email domains for one complaint. The page promises an answer in 7 or 14 calendar days, where clause 29.2 allows four weeks.

Exhibit 11WarningHarder than usual

Any Complaints shall be addressed to the Company’s Compliance Department, an independent department within the Company, to the electronic mail (e-mail) address complaints@brokstock.co.za and info@brokstock.co.za.
Clause 29.1 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.54
Downloaded from the broker's site on Open the reference

Pre-ordering the BROKSTOCK card makes you cover the company against any claim connected to the card's issuance, delay or use, unless the cause was gross negligence or wilful misconduct. The pre-order binds BROKSTOCK to nothing in return.

Why this matters

The document still promises cards in Q3 2025 and asks for a R5 000 deposit to lock in EarlyBird benefits. No funds you send are set aside for the card.

Exhibit 12WarningHarder than usual$5000

By participating in the pre-order process, the client agrees to indemnify, defend, and hold harmless BROKSTOCK SA (Pty) Ltd., its officers, employees, and affiliates from and against any claims, liabilities, damages, losses, or expenses (including legal fees), arising out of or in connection with the issuance, delay, or use of the Card, except where caused by gross negligence or willful misconduct on the part of BROKSTOCK.
Clause 4.4 in Public Offering Document For Pre-Ordering Of BROKSTOCK Branded Banking Cards, p.2
Read from the broker's site on Open the reference

BROKSTOCK can hand your agreement to anyone

Clause 28.5 lets BROKSTOCK assign or transfer its rights and obligations under your agreement to any legal or natural person, at any time, without asking you. Clause 26.3.14 lets it pass your personal data to a buyer on 15 business days notice. We did not read the governing law section of the agreement.

Who holds the contract1 clause flagged

BROKSTOCK can assign or transfer any of its rights and obligations under your agreement to any legal or natural person, at any time, under clause 28.5. Your consent is not part of it.

Why this matters

The company you chose can pass the relationship to a party you did not. Clause 26.3.14 lets it hand your personal data to a buyer on 15 business days notice.

Exhibit 20WarningHarder than usual15 working days

The Company may, at any time, assign and/or transfer to any legal or natural person any of its rights and/or obligations as they arise or are provided for in this present Agreement.
Clause 28.5 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.54
Downloaded from the broker's site on Open the reference

Your cash funds arrangements BROKSTOCK earns from

Clause 15.9 lets BROKSTOCK place your uninvested money with its partners and integrated brokers, and clause 15.6 accepts those holders may have a lien over it. If one fails, clause 15.2 disclaims responsibility for the loss. Clause 10.1 says BROKSTOCK is never your counterparty, while clause 25.1.1.8 says it may match your order with another client's.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Whose side1 clause flagged

Every order goes to a liquidity provider and BROKSTOCK is never a counterparty or principal, says clause 10.1. The conflicts list at clause 25.1.1.8 then says BROKSTOCK may match your order with another client's, acting for both of you.

Why this matters

Who you traded against decides what your price meant. The two clauses cannot both be true, and the site footer repeats the stronger one.

Exhibit 16WarningHarder than usual

The Company acts solely as an intermediary and does not, under any circumstances, act as a counterparty or principal to client trades.
Clause 10.1 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.22
Downloaded from the broker's site on Open the reference

Three quiet months start a monthly charge

50 ZAR a month is charged on any BROKSTOCK account with no trade, no open position and no payment for three months, under clause 17.2. The charge repeats every month until you trade again or the account closes. After a year of inactivity, clause 17.3 lets BROKSTOCK terminate the account.

Dormancy1 clause flagged

Three months with no trade, no open position and no payment in or out makes your account Inactive under clause 2.1.27. BROKSTOCK then charges 50 ZAR a month, and clause 17.2 keeps charging until you trade again or the account closes.

Why this matters

A balance you left alone pays R50 every month it stays quiet. After a year of inactivity, clause 17.3 lets BROKSTOCK close the account.

Exhibit 9WarningStandard wording$50

The administrative fee in amount of 50 ZAR will be charged monthly for any Trading Account that is deemed Inactive Trading Account. This fee will continue to be applied each month until Trading Account activity resumes or the Client’s account is closed.
Clause 17.2 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.39
Downloaded from the broker's site on Open the reference

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
After 3 months of no activityThe account becomes Inactive and the 50 ZAR monthly fee starts.17.1
Every month after thatAnother 50 ZAR is charged until you trade again or the account is closed.17.2
After 1 year of no activityBROKSTOCK may terminate the trading account.17.3

One South African entity, one FSCA licence

BROKSTOCK SA (Pty) Ltd holds FSCA licence FSP 51404 and is the only entity named in the agreement, under clauses 1.1 and 1.2. It renders intermediary services only and names no compensation scheme. Its published complaints procedure still runs in the name of BCS Markets SA (Pty) Ltd.

Who you contract with1 clause flagged

You contract with BROKSTOCK SA (Pty) Ltd, registration 2020/523823/07, licensed by the FSCA as FSP 51404 under clauses 1.1 and 1.2. It renders intermediary services only. Its published complaints procedure still runs in the name of BCS Markets SA (Pty) Ltd.

Why this matters

One entity and one licence, with no offshore company in the agreement to complicate a claim. The name on the complaints page shows how closely the published documents are kept current.

Exhibit 21NoticeStandard wordingNew

BROKSTOCK is a brand operated by BROKSTOCK SA (Pty) Ltd, a company incorporated and registered under the laws of South Africa and a financial services provider regulated by the Financial Sector Conduct Authority ("FSCA") with licence number 51404.
Clause 1.2 in BROKSTOCK SA (Pty) Ltd Service Agreement & Terms and Conditions, p.4
Downloaded from the broker's site on Open the reference

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

The page selling withdrawals says you can take your money out at any time, and the agreement charges 10% if you do it inside 30 days.

Said in public, in English

Start trading now! Open your live account, verify your details and deposit funds using your bank card or Capitec Pay. You can easily withdraw your money at any time.

Opening lines of the Deposits and withdrawals page, above a withdrawal panel showing 0% commission

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of brokstock.co.za

In the contract · clause 16.21

Early Withdrawal Fee will be charged in amount of 10% on any funds withdrawn within 30 days of deposit

02

The Packages page promises no additional fees while the agreement charges up to 2% on the same uninvested funds it pays interest on.

Said in public, in English

No additional fees — just the opportunities for your growth

Packages page, under the heading Manage Your Package Advantage

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of brokstock.co.za

In the contract · clause 15.14

Client also acknowledges that the Company has the right and will apply a service administration fee of up to 2% when the client uninvested funds are held through any Liquidity Provider.

03

The deposits page says BROKSTOCK charges nothing to deposit, and the agreement reserves a processing fee on deposits at its sole discretion.

Said in public, in English

BROKSTOCK does not charge any fees for deposits. However, your bank may apply its own fees or charges.

Deposits and withdrawals page, notes under EFT Transaction

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of brokstock.co.za

In the contract · clause 16.16

The Company reserves the right, at its sole discretion, to apply Payment Processing Fee as a reasonable and transparent platform service fee covering the integration, maintenance, and processing of deposits.

04

The homepage credits your deposits to one South African bank, and the agreement lets BROKSTOCK place your money with partners and integrated brokers.

Said in public, in English

Deposits are safely handled by Standard Bank

Homepage trust panel, under the heading Your Money is Secure

In the contract · clause 15.9

The Company is authorised to deposit client funds with existing company’s partners, integrated brokers, and any future similar partners for the purpose of providing additional earning capabilities to its clients.

05

The footer says BROKSTOCK is never a counterparty, and the conflicts clause says it may match your order with another client's on both sides.

Said in public, in English

Therefore, BROKSTOCK SA (PTY) LTD t/a BROKSTOCK does not act as the principal or the counterparty to any of its transactions.

Regulatory footer, repeated on every page of the site

In the contract · clause 25.1.1.8

The Company may be matching the Client's orders with that of another Client by acting on such other Client's behalf as well as on the Client's behalf.

06

The agreement gives one complaints address and the page it sends you to gives another, in the name of a company BROKSTOCK no longer uses.

Said in public, in English

The complaint should be sent to the email address of the BCS Markets SA (Pty) Ltd complaints@bcsmarkets.co.za.

Complaints procedure page that clause 29.3 of the agreement points clients to

In the contract · clause 29.1

Any Complaints shall be addressed to the Company’s Compliance Department, an independent department within the Company, to the electronic mail (e-mail) address complaints@brokstock.co.za and info@brokstock.co.za.

What changed quietly

First reading of BROKSTOCK, so there is no earlier version of this page to compare it with.

  • ADDEDClause 1.5 · October 2025 to August 2026

    The current agreement adds a flat statement that BROKSTOCK gives no advice or recommendations, while clauses 6.5 to 6.8 still describe advisors it chooses and pays.

    The Company, as a licensed Financial Services Provider (FSP), renders intermediary services only. This means that the Company’s role is limited to facilitating transactions and providing access to financial products,and no financial advice, guidance or recommendations are offered to clients under any circumstances.

  • REWRITTENClause 1.10 · October 2025 to August 2026

    The agreement now covers companies as well as individuals, which brings corporate verification duties and the new termination triggers in clause 23.5.

    The Client may be individual or a legal entity, represented by its Authorised Representative and completes this Agreement through our electronic client onboarding process rather than in person, the Company will, upon request, provide a Portable Document Format (PDF) version of the Agreement documents via email.

  • ADDEDClause 1.12 · October 2025 to August 2026

    BROKSTOCK's own record of your click is now the formal proof that you accepted the terms, and it sets the start date of the contract.

    The acceptance of the Terms and Conditions shall be completed electronically through the Client’s digital onboarding process. The date and time of acceptance shall be automatically recorded and stored within the Company’s Client Relationship Management (CRM) system, serving as formal proof of acknowledgment and agreement by the Client.

The documents this reading is based on

52 files, all published by BROKSTOCK. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording BROKSTOCK publishes.

How this reading was done

Every clause above was read out of a document BROKSTOCK publishes itself

This reading was published on .

Documents
2 of 52downloaded from the broker's site, and 2 read in full
Pages opened
27pages walked to find those documents, footer links included
Older copies
1earlier versions downloaded, 1 identical to the copy we hold by fingerprint
Marketing pages
11public pages set against what the contract says

Who the contract is with

BROKSTOCK SA (Pty) Ltd

You contract with BROKSTOCK SA (Pty) Ltd, a South African company with registration number 2020/523823/07, licensed by the Financial Sector Conduct Authority as FSP 51404. It is the only entity in the agreement, and no offshore company appears anywhere in it. BROKSTOCK's own legal page still links a change of name notice from BCS Markets SA to BROKSTOCK, and the complaints procedure it publishes today is still written in the name of BCS Markets SA (Pty) Ltd.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

BROKSTOCK publishes 51 legal files on one page, plus a dated archive of expired versions, which is more than most brokers show. Clause 16.8 commits to processing a withdrawal within three business days. Clauses 15.1 and 15.4 keep client money segregated from the company's own money. Clause 10.20 gives retail clients negative balance protection, so a loss cannot normally take you below zero. The deposits page states the 1% card fee, the minimums, the maximums and the timings in plain numbers. The complaints page names the FAIS Ombud and gives you six months to go there after a dismissal.

We read the December 2025 service agreement almost end to end, but not its final sections. Applicable law and jurisdiction, restrictions on use, the client declaration and the list of liquidity providers were not read, so this report says nothing about which courts govern your account. We read the card pre-order document in full. We did not read the other 48 files on BROKSTOCK's legal page, among them the client complaints policy, the general risk disclosure, the conflict of interests policy, the privacy policy, the FAIS disclosure document and every promotion's terms. We read the complaints procedure on BROKSTOCK's own web page instead, and the quotations credited to it come from that page. The archived October 2025 agreement would not open past its opening pages, so we cannot tell you which fees in section 16 are new and which were always there. BROKSTOCK publishes in English only, so there was no second language version of its marketing to hold against the contract.

How to check any of this yourself

Every quote above links to the BROKSTOCK file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document BROKSTOCK publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge BROKSTOCK on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Aug 23, 2026.

If you represent BROKSTOCK and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on BROKSTOCK. Whether its licence is real and current is a separate check on the broker profile.

Back to the BROKSTOCK profile