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Contract reading

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

Every clause below is published by ICAP 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: TP ICAP Group plc

deemed acceptancehidden feesole discretionclient moneycost disclosurecounterparty riskno noticeunilateral amendmentbroken referenceclient categorisation

TP ICAP does not deal with individuals. It says on its own website that any investment offer made to an individual in its name is fraudulent. For the firms it does deal with, the terms are hard. Your cash is not payable while anything is owed anywhere in the group. The platform terms that override the main contract can be rewritten by updating a web page. They cap what TP ICAP owes you at the amount you paid to reach that page.

Back to ICAP

Contract risk

Harder than average
5.5/10

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.
27
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
65
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
3

How the 27 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
Warning17
Notice4

section 53 of 55is where the deepest clause sits, 96% of the way into the document it is in

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.

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

Critical8In the contract. Jump to the clause this comes from.Client money protection depends on which company books your trade10 daysAccount limit. Jump to the clause this comes from.Platform access can end for any or no reason30 working daysWithdrawal limit. Jump to the clause this comes from.Brokerage TP ICAP overcharged takes 30 business days back60 daysFee you were not shown. Jump to the clause this comes from.You consent to a limited version of cost disclosure

What the documents say

27 clauses worth knowing about, worst first, each quoted from ICAP's own files

01

Clause 43.9 names two of the eight UK companies that hold no client money and have no FCA permission to hold any. The EU company holds none at all. TP ICAP decides which company serves you and tells you in writing.

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.

Why this matters

The protections you read in clause 43 may not apply to the company that ends up holding your cash. In Dubai it is worse: TP ICAP applies the label Market Counterparty, and if you do not object it may mix your money with its own and use it in its business.

Exhibit 2CriticalHarder than usual8

For the avoidance of doubt, the TP ICAP Providers listed in 3.2(i) and 3.2(iv) do not hold Client Money in the course of providing Broking Services, do not have permission from the FCA to hold Client Money, and Clauses 43.1 to 43.8 do not apply.
Clause 43.9 in TP ICAP Terms of Business, p.40
Read from the broker's site on Open the reference

Buried at section 64 of 69 in the TP ICAP Terms of Business, 93% of the way through.

Set against a regulated standard: FCA (UK)

Firms the FCA licenses must hold client money separately from their own and must hold a permission to hold it at all. Two of the eight companies named here hold no such permission, and the Dubai terms let the firm use a Market Counterparty's money in its own business.

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

02

The Platform Terms of Use beat the Terms of Business wherever they conflict, under clause 44.2. TP ICAP can rewrite them at any time by updating its website, with no notice, and continued use counts as your agreement.

Why this matters

You can be bound by terms you have never seen. TP ICAP says checking the website for changes is your job, and clause 20.2 gives every change to the Terms of Business immediate effect as well.

Exhibit 3CriticalHarder than usual

Where there is a conflict between these Terms of Business and the Terms of Use then the latter shall prevail.
Clause 44.2 in TP ICAP Terms of Business, p.40
Read from the broker's site on Open the reference

Buried at section 64 of 69 in the TP ICAP Terms of Business, 93% of the way through.

  • Worse together with Exhibit 10The UK Terms of Business also drop the written notice requirement, so neither document promises to tell you when it changes.
  • Same clause as Exhibit 6The same clause 44.2 is what gives the liability cap in the Terms of Use priority over the liability clause you negotiated.
03

Cash standing to your credit is not due and payable to you while any sum is owed to any TP ICAP company, under clause 12.2. Paying it out is then at TP ICAP's own discretion.

Why this matters

A contested invoice from another company in the group is enough to stop your own balance being payable. TP ICAP may still choose to pay you, and nothing in the clause requires it to.

Exhibit 4CriticalHarder than usual

Until you have paid or discharged in full all monies and liabilities owed to us (or any other TP ICAP Group Company) any monies from time to time outstanding to the credit of any of your accounts with us (or any other TP ICAP Group Company) shall not be due and payable although we may in our reasonable discretion make payments to you from such accounts, or otherwise exercise our rights of set off and/or combination and/or consolidation.
Clause 12.2 in TP ICAP Terms of Business, p.15
Read from the broker's site on Open the reference

Where it sits: section 24 of 69 in the TP ICAP Terms of Business, 35% of the way through.

  • Worse together with Exhibit 5While your balance is unpayable TP ICAP can also net it against your affiliates' accounts, and you have no matching right.
04

Clause 13.1 lets TP ICAP net, set off, combine or consolidate any of your accounts and any account of your affiliates, in its sole discretion, at any time, with no notice to you. Clause 13.3 gives you no right of set-off at all.

Why this matters

A debt owed by a sister company of yours can be taken out of your own balance, and you will not hear about it first. The right runs one way: you cannot answer a demand by pointing at money the group owes you.

Exhibit 5CriticalHarder than usual

we shall have the right in our sole discretion at any time without notice to you, to net, set-off, combine or consolidate all or any of your accounts with us (or any other TP ICAP Group Company), or any such accounts of your Affiliates, in such manner as we determine, subject to Applicable Regulations.
Clause 13.1 in TP ICAP Terms of Business, p.16
Read from the broker's site on Open the reference

Where it sits: section 26 of 69 in the TP ICAP Terms of Business, 38% of the way through.

05

The Platform Terms of Use say your only remedy for a problem with a trading platform is to stop using it. If a court strikes that out, the fallback cap is whatever you have paid TP ICAP for access, which for the site is nothing.

Why this matters

A platform failure in the middle of a trade leaves you no claim worth bringing. Both documents hold that line only as far as the law allows, and clause 15.4 of the Terms of Business still preserves your claim for a breach of FCA rules.

Exhibit 6CriticalRarely seen

Your sole remedy for dissatisfaction with the Site, any Platform contained on the Site, and/or Information contained on the Site is to stop using the Site, such Platform, and/or such Information, as applicable.
Clause Disclaimer of Damages and Limitation of Liability in Terms of Use
Read from the broker's site on Open the reference
Our own capture of tpicap.com, taken on Oct 14, 2026Liability capped at what you paid to reach the site (clause Disclaimer of Damages and Limitation of Liability)Visit this page on the broker's siteDownload the full size image file
06

TP ICAP deals only with professional firms and large institutions. If you ask to be treated as a retail client, clause 5.3 of the UK terms says it cannot deal with you at all.

Why this matters

If anyone offers you an ICAP or TP ICAP trading account, a managed portfolio or an investment product as an individual, TP ICAP says it is a fraud. Its own fraud page calls any investment opportunity aimed at individual investors in its name fraudulent.

Exhibit 1WarningStandard wording

If you request categorisation as a retail client we will not be able to deal with you.
Clause 5.3 in TP ICAP Terms of Business, p.10
Read from the broker's site on Open the reference

Where it sits: section 16 of 69 in the TP ICAP Terms of Business, near the start.

You must object to a confirmation immediately, and the recordings are treated as conclusive

Clause 40.2 of the UK terms binds you to a confirmation unless you object immediately on receipt. No number of days is given. TP ICAP's own recordings are conclusive evidence of what you instructed. The Platform Terms of Use cap what TP ICAP owes you at the amount you paid for access.

Challenging a trade3 clauses flagged

You have to tell TP ICAP immediately on receipt if you disagree with a confirmation. Stay quiet and clause 40.2 makes it binding on you, with no number of days given anywhere.

In plain words

A manifest error means an obvious mistake by the broker.

Why this matters

A pricing error you spot a week later is already agreed. TP ICAP's own recordings then decide what you instructed, because clause 35.7 makes them conclusive evidence and its sole property.

Exhibit 7CriticalHarder than usual

You will notify us immediately upon receipt if you are not in agreement with any Confirmation or other notification from us. In the absence of such immediate notification by you, the Confirmation or notification will (in the absence of manifest error) be binding on you.
Clause 40.2 in TP ICAP Terms of Business, p.37
Read from the broker's site on Open the reference

Buried at section 59 of 69 in the TP ICAP Terms of Business, 86% of the way through.

TP ICAP accepts no liability for your loss except where it was caused by gross negligence, wilful default, fraud or a breach of FCA rules, under clause 15.2. Plain carelessness is not on that list.

Why this matters

A mistake by a broker that costs you money is not actionable unless you can show it was gross. Clause 15.7 then has you state that these limits are reasonable, which is the first thing TP ICAP would quote if you challenged them.

Exhibit 8WarningHarder than usual

Neither we nor our directors, officers, employees, agents nor any other TP ICAP Group Company shall be under any liability whatsoever for any loss or damage sustained by you as a result of or in connection with the services to which these Terms apply and the provisions contained in these Terms except insofar as, and then only to the extent that, such loss or damage is caused by gross negligence or wilful default, or fraud, or any failure to comply with the FCA Rules or the provisions of the Financial Services and Markets Act 2000 (FSMA).
Clause 15.2 in TP ICAP Terms of Business, p.22
Read from the broker's site on Open the reference

Where it sits: section 35 of 69 in the TP ICAP Terms of Business, 51% of the way through.

TP ICAP promises to handle complaints fairly and promptly, and sets no deadline of its own for answering you. Clause 18.3 keeps the detail, including whether you can go to the Financial Ombudsman Service, for when you ask or when it acknowledges your complaint.

Why this matters

You cannot tell from the contract how long TP ICAP has to answer, or whether anyone outside the firm will look at your case. The Dubai and Norwegian versions of the same clause name no outside route at all.

Exhibit 9WarningHarder than usual

Further details of the complaints-handling process, including information about our complaints management policy and when and how you may be able to refer your complaint to the Financial Ombudsman Service, will be provided to you on request or otherwise when acknowledging your complaint.
Clause 18.3 in TP ICAP Terms of Business, p.25
Read from the broker's site on Open the reference

Where it sits: section 40 of 69 in the TP ICAP Terms of Business, 58% of the way through.

Set against a regulated standard: FCA (UK)

Firms the FCA licenses must deal with a complaint from an eligible complainant to a set timetable and must tell that person about the Financial Ombudsman Service. This contract sets no timetable and gives the detail on request.

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

ICAP sells trade advisory, and the contract excludes advice and any duty to you

The ICAP about us page sells an integrated approach to trade advisory. Clause 34.2 of the UK terms says TP ICAP will not give you investment advice and owes you no fiduciary duty. Clause 9.1 has you warrant that every trade is your own independent judgement.

Advice, or not1 clause flagged

The ICAP about us page sells an integrated approach to trade advisory. Clause 34.2 of the UK terms says TP ICAP will not give you investment advice and owes you no fiduciary duty.

Why this matters

Anything a broker tells you about a trade carries no responsibility, because clause 9.1 has you warrant that every transaction is your own independent judgement. Clause 10.1 then deems the service appropriate for you whenever the rules ask TP ICAP to check.

Exhibit 25WarningHarder than usual

except in circumstances where we expressly agree otherwise, we shall not provide you with any investment advice (as such term is defined in FCA Rules) under these Terms;
Clause 34.2(v) in TP ICAP Terms of Business, p.32
Read from the broker's site on Open the reference
Our own capture of icap.com, taken on Oct 14, 2026The claim, on ICAP About Us pageVisit this page on the broker's siteDownload the full size image file

Buried at section 51 of 69 in the TP ICAP Terms of Business, 74% of the way through.

You agree to a limited version of the cost disclosure the rules would give you

Clause 7.1 of the UK terms has you consent to a limited application of the detailed requirements on costs and charges. Clause 8.2 points to a web page for the inducements disclosure, and that page does not carry one. What you pay is confidential information under clause 23.2, so you may not discuss your rates.

Cost disclosure4 clauses flagged

Clause 7.1 has you agree, as far as the law allows, to a limited application of the detailed requirements on costs and charges. The same clause lets TP ICAP tell you its rates verbally.

Why this matters

You give up the itemised breakdown of what a trade costs you before you place it. Clause 7.4 also reserves interest on anything unpaid after 60 days and never says at what rate.

Exhibit 13WarningHarder than usual60 days

Without prejudice to these obligations, you agree to the fullest extent permissible under Applicable Law to a limited application of the detailed information requirements on costs and associated charges and consent to us providing you information under this Clause 7.1 on such basis.
Clause 7.1 in TP ICAP Terms of Business, p.11
Read from the broker's site on Open the reference

Where it sits: section 18 of 69 in the TP ICAP Terms of Business, 26% of the way through.

Set against a regulated standard: FCA (UK), ESMA (EU)

Firms the FCA licenses must give a client the costs and charges of a service in good time, aggregated and in cash terms. The rules let a professional client or an eligible counterparty agree to a limited version of that, and this clause is where you agree to it.

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

  • Worse together with Exhibit 16You get no detailed breakdown of what you pay, and you are also barred from discussing your rates with anyone.

Clause 8.2 sends you to the TP ICAP regulatory hub for the details of what third parties pay it for your business. That page carries the Asia Pacific terms and two Asia Pacific policies, and nothing about inducements.

Why this matters

You cannot see what TP ICAP is paid for introducing or routing your business, because the one place the contract points to does not carry it. The same page is named in clause 34.3 as the home of the risk notice, which is not there either.

Exhibit 14WarningHarder than usual

We will provide you with further details about our arrangements in relations to such fees, commissions and non-monetary benefits through https://tpicap.com/tpicap/regulatory-hub (our Inducements Disclosures).
Clause 8.2 in TP ICAP Terms of Business, p.12
Read from the broker's site on Open the reference

Where it sits: section 19 of 69 in the TP ICAP Terms of Business, 28% of the way through.

  • Worse together with Exhibit 23An eligible counterparty loses the right to be told about inducements, and the page that would have told everyone else does not carry them.

The Spanish branch terms let TP ICAP convert your currency without telling you first, acting as principal, at a rate it sets. Clause 41.6 then lets it keep any profit it makes on the conversion.

Why this matters

The conversion margin is a cost you never see as a fee, and you carry the exchange risk either way. The UK terms work the same way in a default: TP ICAP picks the currency, sets the rate and takes the conversion cost out of what it owes you.

Exhibit 15WarningHarder than usual

We shall be entitled, without prior notice to you, to make the currency conversions necessary or desirable for the purposes of fulfilling your trading obligations. Any such conversion shall normally be made by us, as principal, at a rate which reflects the size, liquidity and timing of the transaction.
Clause 41.6 in ICAP Energy AS, Sucursal en Espana Terms and Conditions of Business, p.26
Read from the broker's site on Archived copyOpen the reference

Buried at section 85 of 98 in the ICAP Energy AS, Sucursal en Espana Terms and Conditions of Business, 87% of the way through.

Clause 23.2 makes the fees and commissions you pay confidential information, alongside the terms themselves. Clause 22.1 goes further on price data: you may not tell anyone that TP ICAP supplies it to you.

Why this matters

You cannot compare your rates with another firm's, or tell a peer what you were charged, without being in breach. Benchmarking your own costs is the normal way to find out you are paying too much.

Exhibit 16NoticeHarder than usual

all non-public information that is stated to be or that can reasonably expected to be of a confidential or trade secret nature in any form obtained by a party from the other party in the performance of these Terms including, but not limited to, any processes, financial information or data, proprietary data, information or documents and these Terms, all information regarding the System and the fees or commissions payable by the Participant hereunder
Clause 23.2 in TP ICAP Terms of Business, p.28
Read from the broker's site on Open the reference

Buried at section 45 of 69 in the TP ICAP Terms of Business, 65% of the way through.

Money in your account is not payable while the group says you owe anything

Clause 12.2 of the UK terms makes the cash standing to your credit not due and payable while any sum is owed to any TP ICAP company. Paying it out is then at TP ICAP's own discretion. Where TP ICAP finds it has overcharged you, clause 7.5 gives it 30 business days to send the money back.

Getting your money out1 clause flagged

Where TP ICAP finds it has overcharged you and chooses not to set the money off, clause 7.5 gives it 30 business days to send it back. Until then the money is not treated as client money.

Why this matters

Your own money, which TP ICAP agrees it should not have taken, can sit on its balance sheet for six working weeks with no client money protection around it. Only if TP ICAP misses its own deadline does the protection start.

Exhibit 12WarningHarder than usual30 working days

We will not treat the reimbursement of any overpayment as Client Money and will reimburse you within thirty (30) business days.
Clause 7.5 in TP ICAP Terms of Business, p.11
Read from the broker's site on Open the reference

Where it sits: section 18 of 69 in the TP ICAP Terms of Business, 26% of the way through.

TP ICAP will not deal with individuals, and can end a firm's access without a reason

Clause 5.3 of TP ICAP's UK terms says that if you ask to be treated as a retail client, it cannot deal with you. For the firms it does deal with, the Platform Terms of Use let TP ICAP end access at any time, for any or no reason, with no notice. Only TP ICAP can terminate that agreement.

Who may be a client4 clauses flagged

Five of TP ICAP's six sets of terms say it may amend them by written notice to you. The UK set drops that phrase, and clause 20.2 gives every change immediate effect.

Why this matters

If a UK TP ICAP company books your trades, the contract does not promise to tell you when it changes. The Dubai, EU, Asia Pacific, Norwegian and Spanish versions of the same clause still do.

Exhibit 10WarningHarder than usual

We may, from time to time, make such modifications, amendments and additions to these Terms as we consider necessary or desirable, including those required in order to comply with any applicable law or the requirements of any governmental or other regulatory body or to comply with the rules of a Trading Venue or third country equivalent or Infrastructure.
Clause 20.1 in TP ICAP Terms of Business, p.26
Read from the broker's site on Open the reference

Buried at section 42 of 69 in the TP ICAP Terms of Business, 61% of the way through.

TP ICAP can terminate the Platform Terms of Use, or cut your access to any part of the site or platform, at any time, in its sole discretion, for any or no reason, with no notice to you. Only TP ICAP can end that agreement.

Why this matters

Your screens can go dark without warning while you still owe TP ICAP everything you traded before. There is a 10 day window to fix a suspected breach, but TP ICAP decides whether to give you notice of one and whether your fix worked.

Exhibit 11WarningHarder than usual10 days

TP ICAP shall have the right to terminate this Agreement (in whole or in part), and/or terminate, limit or suspend your access to and use of any part of the Site, Information, and/or any Platform, at any time in its sole discretion, for any or no reason, and without the requirement of providing any notification to you.
Clause Termination in Terms of Use
Read 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
Suspected breachTP ICAP may tell you it suspects a breach, and may choose not to.Suspension
Day 10Your window to fix the suspected breach closes, and TP ICAP alone judges whether you did.Suspension
Breach shownTP ICAP can end the agreement at once with no further obligation to you.Suspension

The Platform Terms of Use bar you from using TP ICAP data in support of your trading with, or your provision of liquidity to, any competitor of TP ICAP. The word competitor is not defined anywhere in the document.

Why this matters

Taking prices from TP ICAP limits where you may deal, not just who you may pass the prices to. Breaching it lets TP ICAP cut your access and bill you for the audit that found it.

Exhibit 26WarningRarely seen

(iv) use the data in support of your trading activities with, or the provision of liquidity to, any competitor of TP ICAP; and (v) use the data for any illegal purpose or in a manner that brings TP ICAP or any of its Affiliates or its or their respective businesses or markets into disrepute.
Clause Information Terms in Terms of Use
Read from the broker's site on Open the reference

Clause 35.8 says TP ICAP has no obligation to accept a dealing instruction and need not give reasons for turning one down. Clause 11.4 lets it withdraw a service over a conflict of interest and keep the reason to itself.

Why this matters

An order can be declined, or a service pulled, with no explanation you can test or appeal. TP ICAP also disclaims responsibility for what a refusal or a delay costs you while the market moves.

Exhibit 24NoticeStandard wording

We shall not be under any obligation to accept a dealing instruction from you nor need we give any reasons for declining to do so and, where we do accept a dealing instruction from you, we shall seek to action it as soon as reasonable practicable.
Clause 35.8 in TP ICAP Terms of Business, p.35
Read from the broker's site on Open the reference

Buried at section 56 of 69 in the TP ICAP Terms of Business, 81% of the way through.

Two live TP ICAP contracts cover the same office under different laws

One address in Copenhagen appears in two live sets of TP ICAP terms. The UK set puts it under English law and the English courts. The EU set puts it under French law and the Paris commercial court. You must sue in England, and TP ICAP may sue you anywhere.

Which law, which court2 clauses flagged

The same Copenhagen address sits in TP ICAP's UK terms, under English law and the English courts, and in its EU terms, under French law and the Paris commercial court. One Bergen address appears in two sets of terms the same way.

Why this matters

Which law governs your dealings, and which country you would have to sue in, depends on which group company books the trade. Clause 2.1 says TP ICAP tells you which one that is in writing from time to time.

Exhibit 18WarningHarder than usual

Name of the branch: TP ICAP Commodities, Copenhagen Branch of TP ICAP Commodities Limited, United Kingdom Address of the branch: Rentemestervej 14, 2400 København, Denmark
Clause Schedule 1 in TP ICAP Terms of Business, p.43
Read from the broker's site on Open the reference

Buried at section 53 of 55 in the TP ICAP Terms of Business, 96% of the way through.

  • Worse together with Exhibit 2The company that decides your governing law also decides whether your cash is held as client money at all.

Clause 33.2 of the UK terms gives the English courts exclusive jurisdiction over your claims, then reserves TP ICAP's right to bring proceedings against you in any other court. Clause 27.1 lets it hand your contract to another group company without asking you.

Why this matters

Wherever you are, a claim against TP ICAP means litigating in London. A claim against you can be brought at home, and the company on the other side of your contract can change without your consent.

Exhibit 19WarningStandard wording

You agree that the courts of England are to have exclusive jurisdiction to settle any disputes, which may arise out of or in connection with these Terms. Nothing contained in this Clause 33 shall limit our right to take proceedings against you in any other court of competent jurisdiction.
Clause 33.2 in TP ICAP Terms of Business, p.31
Read from the broker's site on Open the reference

Buried at section 50 of 69 in the TP ICAP Terms of Business, 72% of the way through.

TP ICAP can audit your records at your expense and sell the data your trading makes

The Platform Terms of Use give TP ICAP 30 days of notice to audit your records, and your subcontractors' records, at your own expense. Clause 44.15 of the UK terms adds a review of your internal risk controls. Clause 17.4 grants TP ICAP a perpetual licence to sell the data your trading generates.

Information and audit2 clauses flagged

The Platform Terms of Use let TP ICAP demand access to your accounts and records, and to your subcontractors' records, on 30 days of notice and at your expense. If it finds a breach it charges you the cost of the audit as well.

Why this matters

You pay for the inspection that checks up on you, and the right lasts a year after you stop using the platform. Clause 44.15 of the UK terms adds a review of your internal risk controls whenever TP ICAP thinks it necessary.

Exhibit 21WarningHarder than usual30 days

Upon thirty (30) days’ written notice, at your own expense, at all reasonable times you shall permit TP ICAP to have access to and/or provide to TP ICAP accounts, records and other information reasonably required by TP ICAP (whether controlled by you or any of your affiliate’s or your, its or their subcontractors) relating to, your access and/or use of the Information in order to verify your compliance with this Agreement.
Clause Audit in Terms of Use
Read from the broker's site on Open the reference

Clause 17.4 grants TP ICAP a perpetual, worldwide, royalty free licence to use, sub-licence and sell the data you submit and the price and volume information from your trades. It may also name you to anyone as a client.

Why this matters

Your trading activity becomes a product TP ICAP sells, for as long as it likes, and you are not paid for it. The group has to aggregate the data before selling it, and the EU version of the same clause stops after 20 years rather than running forever.

Exhibit 22WarningHarder than usual

You acknowledge and agree that we shall be permitted, and you grant us a non-exclusive, perpetual, transferable, world-wide and royalty-free licence (without warranties of any kind, express or implied), to use, distribute, sub-licence, and sell for the benefit of the TP ICAP group any data provided by yourself (including via submission to the System)
Clause 17.4 in TP ICAP Terms of Business, p.24
Read from the broker's site on Open the reference

Where it sits: section 39 of 69 in the TP ICAP Terms of Business, 57% of the way through.

Asking to be an Eligible Counterparty switches off best execution and inducement disclosure

Clause 5.2 of the UK terms lists what an Eligible Counterparty gives up. Best execution goes, so does the limit on inducements and the duty to act in your best interests. Clause 8.1 then removes the disclosure of what third parties pay TP ICAP for your business.

What a label costs1 clause flagged

Clause 5.2 of the UK terms lists what an Eligible Counterparty gives up. Best execution goes, so does the limit on inducements and the duty to act in your best interests. Clause 36.6 confirms the execution policy stops applying to you.

Why this matters

Once you carry that label TP ICAP owes you no duty to get you the best result, and clause 8.1 removes the disclosure of what third parties pay it for your business. In Dubai the label is applied by TP ICAP and silence keeps it.

Exhibit 23WarningStandard wording

If you request categorisation as an Eligible Counterparty and we agree to such categorisation, you will lose the protection afforded by certain of the FCA Rules, including:
Clause 5.2 in TP ICAP Terms of Business, p.10
Read from the broker's site on Open the reference

Where it sits: section 16 of 69 in the TP ICAP Terms of Business, near the start.

Set against a regulated standard: FCA (UK), ESMA (EU)

Firms the FCA licenses owe best execution to retail and professional clients. The rules do not extend it to an eligible counterparty, and clause 36.6 takes the execution policy away once you accept that label.

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

Whether your money is protected as client money depends on which TP ICAP company books it

Clause 43.9 of the UK terms names two of the eight UK companies that hold no client money and have no FCA permission to. The EU company holds none at all. In Dubai, TP ICAP applies the label Market Counterparty. If you do not object to it, TP ICAP may mix your money with its own and use it in its business.

Who holds your cash1 clause flagged

Two of the six sets of terms on TP ICAP's legal page are ICAP Energy AS documents dated 3 January 2018. They send you to www.icap.com/regulatorydisclosures for the risk notice, the execution policy and the conflicts policy. There is no page at that address.

Why this matters

If these are your terms, you cannot reach the documents they tell you to read, and they name a holding company, TP ICAP plc, that the newer terms no longer use. Nothing on the page says whether they still apply.

Exhibit 20WarningHarder than usual

if you have explicitly consented to receive a notice of risks by means of a website and you have provided us with your email address, this information will be made available at www.icap.com/regulatorydisclosures or such other website as notified to you by us.
Clause 33.3(ii) in ICAP Energy AS Terms and Conditions of Business, p.23
Read from the broker's site on Open the reference

Buried at section 47 of 72 in the ICAP Energy AS Terms and Conditions of Business, 65% of the way through.

TP ICAP can net your accounts and your affiliates' accounts, and you can net nothing

Clause 13.1 of the UK terms lets TP ICAP net or combine any of your accounts and any account of your affiliates, in its sole discretion and without notice. Clause 13.3 gives you no right of set-off at all. Clause 44.9 lets TP ICAP stop, block or cancel any transaction.

Netting and cancellation1 clause flagged

Clause 44.9 lets TP ICAP stop, block or cancel any transaction on reasonable grounds, including anything in the Rulebook or its error trade policy. The Rulebook prevails over the terms you signed, and TP ICAP writes it.

Why this matters

A trade you believe is done can be unwound under a document you did not negotiate. TP ICAP has to act on reasonable grounds and in line with market convention, which is the real limit on the clause.

Exhibit 27NoticeStandard wording

We shall have the right to stop, block or cancel any transaction on reasonable grounds and in accordance with applicable law and market convention including, without limitation, on any grounds set out in the Rulebook, any applicable error trade policy, manifest error, unauthorised use of any trading algorithm, or market or System abuse or misuse.
Clause 44.9 in TP ICAP Terms of Business, p.41
Read from the broker's site on Open the reference

Buried at section 66 of 69 in the TP ICAP Terms of Business, 96% of the way through.

Set against a regulated standard: FCA (UK), ESMA (EU)

Venue operators under FCA and ESMA rules are expected to publish rules for cancelling erroneous trades. The limit here is that the document holding those rules can be amended by TP ICAP and prevails over the Terms of Business.

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

After six years of no movement your balance can go to a charity TP ICAP picks

Clause 43.7 of the UK terms stops treating your money as client money after six years with no movement on the balance. TP ICAP may then pay it to a registered charity of its choice. It undertakes to pay you the same sum if you later claim it.

Dormant balances1 clause flagged

Clause 43.7 stops treating your money as client money once your balance has not moved for six years, whatever charges or interest ran through it. TP ICAP may then pay it to a registered charity of its choice.

Why this matters

A forgotten balance leaves the protected pot and can be given away. TP ICAP has to write to your last known address first, and it undertakes to pay you the same sum if you later claim it.

Exhibit 17NoticeStandard wording

You consent to us ceasing to treat any money held for you or on your behalf as Client Money where there has been no movement on your balance for a period of at least six years, notwithstanding any payments or receipts of charges, interest or similar items.
Clause 43.7 in TP ICAP Terms of Business, p.39
Read from the broker's site on Open the reference

Buried at section 63 of 69 in the TP ICAP Terms of Business, 91% of the way through.

Where the marketing and the contract disagree

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

01

The Terms of Use call themselves supplementary, while the Terms of Business say the Terms of Use win any conflict.

Said in public, in English

This Terms of Use agreement (the "Agreement") describes your rights and responsibilities and states the terms and conditions under which you may use the Site and is supplementary to our Terms of Business.

Opening section of the Platform Terms of Use on tpicap.com

In the contract · clause 44.2

Where there is a conflict between these Terms of Business and the Terms of Use then the latter shall prevail.

02

The page sorts terms by region, while the UK terms carry their own EU branch in Copenhagen under English law.

Said in public, in English

For services provided by TP ICAP (Europe) S.A in the EU, please refer to the following Terms of Business (pdf).

Terms of Business section of the TP ICAP Legal and Regulatory page

In the contract · clause Schedule 1

This Addendum should be read in addition to and in conjunction with the Terms when services are provided to you by TP ICAP Commodities Limited, Copenhagen Branch of TP ICAP Commodities Limited, United Kingdom.

03

ICAP markets trade advisory while the contract excludes investment advice and any fiduciary duty.

Said in public, in English

Through our expert brokers, and leading technology, clients benefit from our integrated approach to trade advisory, price discovery, and trade execution.

ICAP About Us page

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

In the contract · clause 34.2(v)

except in circumstances where we expressly agree otherwise, we shall not provide you with any investment advice (as such term is defined in FCA Rules) under these Terms;

The documents this reading is based on

65 files, all published by ICAP. 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 ICAP publishes.

How this reading was done

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

This reading was published on .

Documents
9 of 65downloaded from the broker's site, and 9 read in full
Pages opened
52pages walked to find those documents, footer links included
Older copies
2earlier versions downloaded, 2 identical to the copy we hold by fingerprint
Marketing pages
11public pages set against what the contract says
Position measured
23clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

TP ICAP Group plc

No client contracts with TP ICAP Group plc. It is only the holding company named in the terms. The contract is with one of at least eight separate companies: clause 3.2 of the UK terms lists ICAP Global Derivatives Limited, TP ICAP Broking Limited, TP ICAP Commodities Limited, TP ICAP E&C Limited, the London branches of TP ICAP (Europe) S.A. and TP ICAP Global Markets Americas LLC, TP ICAP Markets Limited and TP ICAP MTF Limited. Clause 2.1 says which one serves you is notified to you in writing from time to time. Outside the UK the counterparty is TP ICAP (Europe) S.A., TP ICAP (Dubai) Limited, ICAP Energy AS or an Asia Pacific company, each with a different regulator, a different governing law and a different court. The Platform Terms of Use are granted by a ninth company again, TP ICAP Holdings Limited.

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

TP ICAP publishes six full sets of terms, one per region, each naming its own company, regulator, governing law and court. All are free to download and dated. It states on its own site that it does not serve retail investors, which most firms leave a reader to work out. Clause 7.5 of the UK terms commits TP ICAP to repaying brokerage it overcharged, and to treating that money as client money if it misses its own deadline. Clause 15.4 keeps its liability for breaking FCA rules intact. The EU version caps the licence over your trading data at 20 years rather than forever, and gives 14 days of notice before either side can walk away.

This review covers nine documents in full: the five regional sets of Terms of Business, the Platform Terms of Use, the privacy notice, the anti money laundering statement and the scams page. It covers the Asia Pacific terms only up to clause 21, so the schedule that names the Asia Pacific companies and their regulators is not included. The other 55 files are not covered. Those include the risk disclosure policy, the conflicts of interest policy, the execution and order handling policies, the Liquidnet payment for order flow policy, the Canadian client notices and the financial statements. One file, the ICAP Global Derivatives Limited 2024 report, holds no readable text. Only two earlier copies of any document exist for comparison, and both are identical to the files on the site today. TP ICAP offers two copies of the Asia Pacific terms, filed under different months, and we worked from one. Quoted page numbers are the ones printed at the foot of each page. In the UK terms, these do not match the document's own contents list.

How to check any of this yourself

Every quote above links to the ICAP 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 ICAP 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 ICAP 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 Oct 14, 2026.

If you represent ICAP 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 ICAP. Whether its licence is real and current is a separate check on the broker profile.

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