Home โ€บ Brokers & Platforms โ€บ What Is a Broker's Execution Policy Document?

What Is a Broker's Execution Policy Document?

i Short answer

An execution policy document discloses how a broker handles and fills client orders, including dealing desk practices and pricing sources.

1. What this document typically discloses

A typical execution policy document discloses the broker's general approach to filling client orders, including whether and how it acts as a dealing desk counterparty, which liquidityLiquidity describes how easily an instrument can be bought or sold without significantly affecting its price.Click to read more โ†’ sources or providers it draws from, and its stated commitment to providing reasonably fair pricing and execution under normal market conditions.

It's worth reading this specifically for concrete, verifiable statements rather than general reassurance language. A policy that specifically names its liquidity providers or precisely describes its slippageSlippage tolerance sets the maximum acceptable price deviation before an order is rejected rather than executed at a significantly different price..Click to read more โ†’ handling process gives more genuinely useful information than one that offers only broad, generic commitments to 'fair and transparent' execution without further detail.

!
Unregulated brokers have no SA consumer protection

Using an unregulated offshore broker means SA law does not apply. SARS, FSCA, and SA courts have no jurisdiction. Disputes must go through the overseas regulator only.

ZA
SA-specific: Verify any broker holds a current FSCA FSP licence at fsca.co.za before depositing. The FSP number must appear on the broker's website and marketing materials.

2. Why brokers publish this kind of document

Publishing this kind of disclosure reflects both regulatory expectations around transparency and a broader industry practice of giving clients meaningful information about exactly how their orders are actually processed, rather than leaving this important mechanical detail entirely opaque or undisclosed.

This document is worth treating as one of the more genuinely informative pieces of a broker's legal documentation, precisely because it addresses the practical mechanics of how your actual trades get filled, a detail that matters directly to your day-to-day trading experience in a way that some other, more abstract legal disclosures don't.

Broker Verification Checklist
  • Search FSP name or number at fsca.co.za
  • Confirm licence is current and not suspended
  • Check scope covers forex and CFD activity
  • Confirm client funds in segregated accounts
  • Read FSCA enforcement actions history
  • Test customer support before depositing
Pros
  • Client funds legally segregated
  • FSCA complaints process available
  • SA consumer protections apply
  • ZAR account, no FX conversion costs
Cons
  • Some offshore brokers offer wider instruments
  • Regulatory overhead passed on in spreads
  • Stricter position limits for retail clients
  • FICA verification required before trading
FSCA-regulated
  • Client funds segregated
  • Formal FSCA complaints process
  • SA consumer protections apply
  • ZAR account available
Offshore unregulated
  • Fund safety not guaranteed
  • Overseas disputes only
  • SA law does not apply
  • Currency conversion costs

3. What to specifically look for within it

Worth checking within this document: whether the broker explicitly states its execution model (market maker, ECN, or STP), any specific commitments around slippage handling, particularly during volatile conditions, and any disclosed conflicts of interest related to the broker's business model.

It's worth cross-referencing what this document states against your own actual trading experience once you've been active with the broker for a while. A policy that promises fair handling of volatile conditions is worth more once you've seen it hold up during a genuinely fast-moving session, rather than taking the written commitment alone as sufficient confirmation.

checkmarkFSP licence required
R0cost to verify at fsca.co.za
24hrtypical FSCA complaint acknowledgement
5 yearsFSCA can investigate historical activity
DODON'T
Verify FSP number at fsca.co.za before depositing
Trust marketing alone, always verify independently
Confirm client funds are legally segregated
Assume segregation without reading the client agreement
Use FSCA complaints process for unresolved disputes
Assume offshore brokers have equivalent SA consumer protections
Keep records of all deposits and withdrawals
Deposit more than you can afford to lose entirely

4. How this relates to the market maker versus NDD distinction

This execution policy document is often where a broker explicitly states which of the market maker or no-dealing-desk models applies to your account, giving a more authoritative source for this important detail than relying solely on general marketing claims or third-party comparison sites.

This is worth checking directly rather than relying on a broker's general marketing positioning, since 'ECN-style' or 'STP' branding in promotional material doesn't always precisely match the specific, legally binding description found in the actual execution policy document itself.

FSCA Regulated vs Unregulated
ProtectionFSCA RegulatedOffshore Unregulated
Client fund segregationโœ“ RequiredVaries by broker
SA complaints processโœ“ Availableโœ— Not available
SA consumer law appliesโœ“ Yesโœ— No
ZAR account availableโœ“ TypicallyOften USD/EUR only
FSCA Verification Quick Check
Regulator
FSCA, Financial Sector Conduct Authority
Verify at
fsca.co.za, public FSP register
Licence type
Category I or II FSP
Client funds
Must be segregated
Complaints
fsca.co.za/complaints
Required docs
ID + address proof + bank statement

5. What this document doesn't guarantee

It's worth understanding that an execution policy document describes the broker's general approach and stated intentions, but doesn't guarantee identical, perfect execution on every single trade. Normal market conditions, including genuine liquidity and volatilityVolatility measures how much and how quickly an instrument's price fluctuates.Click to read more โ†’ factors, still apply, meaning some variation in actual execution experience remains normal even under a genuinely fair, well-disclosed policy.

This distinction is worth internalising specifically so that normal, expected execution variation during genuinely volatile conditions doesn't feel like a broken promise. A well-disclosed policy that's honest about this variability is, in a meaningful sense, more trustworthy than one implying perfect, guaranteed execution under all conditions, a standard no broker can genuinely meet.

Example
FSCA regulated: You dispute an incorrect trade execution. You file with the FSCA. The regulator investigates and can require restitution. Unregulated offshore: Same dispute. SA FSCA has no jurisdiction. You must pursue the overseas regulator through their own process.

6. Finding and reviewing your broker's specific policy

Most FSCA-regulated brokers make their execution policy document available directly on their website, often within a legal or regulatory documentation section alongside the broader terms and conditions. Reviewing this directly, rather than relying solely on summarised marketing descriptions, gives the most authoritative, complete picture of your broker's actual execution practices.

It's also worth checking whether a broker offers negative balance protection, a feature many FSCA-regulated brokers now provide as standard, which caps your maximum possible loss at your account balance even during extreme, fast-moving market conditions.

The FSCA regulatory framework provides South African retail traders with meaningful protection that extends beyond simply verifying a broker's licence number. The requirement for FSCA-regulated brokers to maintain segregated client accounts means your deposited funds are legally separated from the broker's operating funds. In the event of broker insolvency, this segregation protects client money from creditor claims against the company. FSCA-regulated brokers must also maintain adequate financial resources, submit to regulatory oversight, and adhere to disclosure requirements covering fees, risks, and conflicts of interest. For traders considering offshore brokers outside FSCA supervision, the loss of these domestic protections is a material risk consideration, particularly for larger account balances where the downside of unregulated broker failure would be financially significant.

The FSCA regulatory framework provides South African retail traders with meaningful protection that extends beyond simply verifying a broker's licence number. The requirement for FSCA-regulated brokers to maintain segregated client accounts means your deposited funds are legally separated from the broker's operating funds. In the event of broker insolvency, this segregation protects client money from creditor claims against the company. FSCA-regulated brokers must also maintain adequate financial resources, submit to regulatory oversight, and adhere to disclosure requirements covering fees, risks, and conflicts of interest. For traders considering offshore brokers outside FSCA supervision, the loss of these domestic protections is a material risk consideration, particularly for larger account balances where the downside of unregulated broker failure would be financially significant.

โ˜… Why It Matters

Worth doing once: actually read this document in full for your own broker, rather than assuming it's standard boilerplate. Execution policies vary more between brokers than their similar-sounding names suggest, and this is the one document that explains exactly how your orders get filled.

Order routing
How orders are handle
Market maker vs NDD disclosed
Slippage policy
How handled
Positive and negative slippage policy
Other sections worth reading
Conflict of interest
disclosed here
Order types supported
listed
Execution venues
listed for NDD brokers
Required by FAIS
must be published

A broker's execution policy document must disclose how orders are routed, how slippage is handled, and conflicts of interest. FAIS requires brokers to publish this and provide it on request.

โœ• Common mistakes

  • Never actually reading this document for your own broker. It explains precisely how your orders get filled, more specifically than most marketing material.
  • Not revisiting this document after a broker updates its policies. Changes here can affect your trading without obvious notice elsewhere.
  • Treating this as irrelevant unless something goes wrong. Understanding it proactively helps set realistic execution expectations.
Do spreads widen during major economic news releases?

Yes. Spreads on most instruments widen during high-impact news as liquidity temporarily decreases. This is most noticeable around central bank decisions, US Non-Farm Payrolls, and major economic data releases.

What causes slippage and how do I minimise it?

Slippage occurs when your order executes at a different price than requested, typically during fast-moving markets. Using limit orders rather than market orders and avoiding order placement immediately around major news releases reduces slippage exposure.

Key Takeaways

  1. An execution policy document discloses how a broker handles and fills client orders, providing transparency around the dealing desk and pricing practices.
  2. An execution policy document discloses how a broker handles and fills client orders, including dealing desk practices and pricing sources.
  3. What this document typically discloses.
  4. Why brokers publish this kind of document.
  5. What to specifically look for within it.

Frequently asked follow-up questions

Is every broker required to publish this kind of document?

Disclosure requirements vary by jurisdiction and regulatory framework. Checking your broker's available documentation directly confirms what they've published.

Can I request this document if I can't find it on my broker's website?

Yes, contacting your broker's support team directly to request this documentation is a reasonable approach if it's not readily visible online.

Does this document explain spread costs specifically?

It typically focuses on execution mechanics rather than detailed fee schedules. Checking your broker's separate fee documentation addresses spread and cost specifics more directly.

๐Ÿ“š Sources & further reading

This article draws on general information published by the South African regulators and established financial education resources listed below. Always check each source directly for the most current detail.

Explore more South African trading guides on TradeAnswers.

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