Terms of business

To open an account you must be at least 18 years old, have full legal capacity, and be resident in a jurisdiction in which we are permitted to offer our services. We do not accept clients resident in the United States, Canada, Japan, Iran or North Korea, and we may decline or close an account from any jurisdiction where offering our services would breach local law.

Before a live account may be funded we are required to verify your identity, your address and, in some cases, your source of funds. Until verification is complete you may hold a demo account but you may not deposit, trade live, or withdraw. We may re-verify at any time and may restrict an account pending review.

1. (a)You must provide accurate, complete and current information, and keep it up to date. Providing false information is a material breach of this Agreement.
2. (b)The account must be opened and operated in your own name. We do not accept third-party payments and we do not permit an account to be operated by anyone other than the account holder, unless a written power of attorney has been accepted by our compliance desk.
3. (c)You are responsible for keeping your credentials secure. We strongly recommend enabling two-factor authentication. Instructions received through your authenticated session are treated as given by you.
4. (d)We may decline an application, at our discretion, without giving reasons.

You will be categorised as a retail client by default, which affords you the highest level of protection, including negative balance protection. If you meet the quantitative and qualitative criteria you may apply to be treated as an elective professional client; doing so reduces the protections available to you and we will explain what you lose before any re-categorisation takes effect.

We offer contracts for difference (“CFDs”) on foreign exchange pairs, spot metals, index CFDs, commodities, crypto-assets and single-name shares. A CFD is an agreement to exchange the difference in the price of an underlying instrument between the opening and closing of the contract. You never acquire, and have no right to acquire, the underlying instrument, and you have no voting, dividend entitlement (beyond a financing adjustment), delivery or ownership rights.

We deal as principal. This means that when you open a position, we are the counterparty to it. Your loss on a contract may be our gain, and our gain may be your loss. Section 4 explains how we manage the conflict of interest that follows from that.

We provide an execution-only service. We do not provide investment advice, portfolio management or personal recommendations, and nothing on our website, in our platform, in our market commentary or in any communication from our staff constitutes advice or a recommendation to enter into any transaction. Any decision to trade is yours alone.

We may, at our discretion, decline to accept any order, limit the size of any position, close a position, or suspend trading in any instrument — for example where a market is disorderly, where a price is manifestly erroneous, or where accepting the order would breach a regulatory or internal risk limit. Where we do so we will notify you as soon as reasonably practicable.

We take all sufficient steps to obtain the best possible result for our clients on a consistent basis. Because we are the sole execution venue for the CFDs we issue, “best execution” is delivered through the quality and fairness of the prices we construct rather than through venue selection.

How our prices are made

Our prices are derived from the underlying market — aggregated from our liquidity providers and reference venues — to which we apply a mark-up that is disclosed in the contract specification for each instrument and in the account type you hold. Spreads are variable. They are typically tightest during the London and New York overlap and widen during thin liquidity, around scheduled economic releases, at the daily rollover, and on any gap.

Execution factors and how we weight them

1. (a)Price — the dominant factor for retail clients. Orders are executed against our two-way price at the moment the instruction is received by our servers.
2. (b)Speed and likelihood of execution — market orders are filled at the price prevailing at receipt; there is no manual intervention and no “last look” delay applied to client orders.
3. (c)Size — orders above the published maximum ticket size for an instrument may be filled in parts at different prices, or rejected.
4. (d)Costs — commission and financing are applied as published, never varied per order.

Slippage

Where the market moves between the moment you submit an order and the moment we receive it, the order may be filled at a different price. Slippage is applied symmetrically: if the market has moved in your favour you receive the better price, and if it has moved against you, you receive the worse price. We do not apply asymmetric slippage, and we do not apply a minimum slippage threshold to positive slippage only.

Pending orders and stops

A stop loss is not a guaranteed order. It becomes a market order when the trigger price is reached, and in a gapping or fast-moving market it may be filled materially worse than the level you set. Limit orders are filled at your specified price or better, or not at all. Pending orders that would be triggered by an opening gap are executed at the first available price after the open, not at the trigger price.

Managing our conflict of interest

1. (a)We hedge net exposure with third-party liquidity providers above defined thresholds, so that our commercial interest is aligned with volume rather than with client losses.
2. (b)Dealing and sales staff are remunerated on volume, retention and service quality. No member of staff is remunerated on client trading losses.
3. (c)Prices, spreads, commission and financing rates are applied by the pricing engine on a per-instrument and per-trading-group basis. Individual client accounts are not repriced, delayed or given a different fill from other clients in the same group.
4. (d)Requotes, rejections and manual interventions are logged with the reason and are available to our compliance desk and to the regulator.

Trading on margin means you post a fraction of the full contract value to open a position. Initial margin is calculated as the notional value of the position multiplied by the instrument’s margin percentage, subject to the leverage ceiling applied to your account. Both figures are published in the contract specification for each instrument and are visible on the order ticket before you confirm.

When your margin level falls to the margin call level shown on your account (100% by default), we will notify you in the platform and by email. A margin call is a warning, not a request for payment, and we are under no obligation to issue one before liquidating: it is your responsibility to monitor your account.

When your margin level falls to the stop-out level shown on your account (50% by default), we will begin closing your open positions automatically, starting with the largest loss, until the margin level is restored above the stop-out threshold. Stop-out is executed by our server-side risk process and does not depend on your browser being open or your device being connected.

Retail clients have negative balance protection. If a gap or an extreme move closes your positions at a level that takes the account below zero, we will write the deficit off rather than pursue you for it. This protection does not prevent the loss of your entire balance, which is the ordinary outcome for the majority of retail CFD accounts.

We may change margin requirements or leverage limits for an instrument, a trading group or an individual account — including in response to volatility, an approaching event, a change in liquidity, or a regulatory requirement. Where we can, we give notice; where market conditions do not permit it, the change may take effect immediately.

There are exactly three trading costs, all disclosed before you confirm an order and itemised on every deal in your history.

1. (a)Spread — the difference between the bid and the ask, incurred when you open a position and again when you close it. Spreads are variable.
2. (b)Commission — charged per standard lot per side. The rate has two components: the commission carried by the instrument you trade, which applies on every account type, and the commission carried by the trading book your account is placed in, which varies by account type and is nil on some. Both are published before you open a position, and their total is charged at execution and shown on the deal as a separate line rather than absorbed into your profit or loss.
3. (c)Overnight financing (“swap”) — applied per lot per night at the daily rollover on positions held open across it, at the long or short rate published in the instrument’s contract specification. Positions held over the Wednesday rollover are charged three nights to cover the weekend value date.

Swap-free accounts are not charged or credited overnight interest. Where a position on a swap-free account is held for more than ten calendar days, a flat administration fee is applied in place of financing; the amount is disclosed on the ticket before the position is opened.

Where the currency in which a profit or loss accrues differs from your account currency, the amount is converted at the prevailing rate with a conversion markup of 0.5%. There is no platform fee, no market data fee, no charge to deposit, and no inactivity fee on a funded account. Withdrawal charges are the published rail fees and nothing else.

Deposits may be made by card, bank wire, crypto transfer or e-wallet, subject to the published minimum and maximum for each rail. Funds are credited to your trading account once received and cleared. We do not accept cash, and we do not accept payments from any person other than the account holder — third-party payments are rejected and returned to source, which may take several weeks and may incur bank charges we cannot recover.

Withdrawal requests are queued for review by our treasury desk. Requests submitted before 14:00 UTC on a business day are ordinarily reviewed the same day. Funds are returned to the same instrument used to deposit, in the account holder’s name, up to the total amount deposited by that instrument; any surplus is returned by bank wire.

1. (a)We may decline or delay a withdrawal where verification is incomplete, where the request would take the account below the margin required by open positions, where we are investigating a suspected breach of this Agreement, or where we are required to do so by law.
2. (b)Card withdrawals settle in one to five business days; bank wires in two to five; crypto transfers within 24 hours; e-wallets within 24 hours.
3. (c)Withdrawal fees are as published on our pricing page and are deducted from the amount withdrawn.
4. (d)Any bonus or credit applied to your account is not withdrawable and is removed at the point of withdrawal in accordance with the terms of the promotion under which it was granted.

Money you deposit is held in client bank accounts segregated from our own funds with tier-1 credit institutions, and is reconciled daily. Segregated client money is not used for hedging, working capital or any other corporate purpose, and is not available to our general creditors in the event of our insolvency.

We do not pay interest on client money balances. Where a client account has been dormant for more than six years and we have been unable to contact you despite reasonable efforts, we may cease to treat the balance as client money, while remaining liable to repay it to you on request.

You are responsible for the security of your account, for the suitability of any strategy you employ, for monitoring your open positions and margin level, and for the tax consequences of your trading.

The following are prohibited and may result in the closure of positions, the reversal of profits obtained through them, restriction of the account, or termination of this Agreement.

• Exploiting a manifest error, a stale or off-market price, a latency arbitrage, or any malfunction of the platform, whether or not you caused it.
• Operating multiple accounts, or coordinating with other account holders, in order to hedge risk-free between accounts or to abuse a promotion, rebate or partner arrangement.
• Trading on the basis of information obtained unlawfully, or in any manner that constitutes market abuse under applicable law.
• Using automated systems that place orders at a rate materially in excess of what a human could submit, without our prior written consent.
• Providing false information, using another person’s payment instrument, or permitting a third party to operate the account.

Where we reverse a transaction under this section we will notify you with an explanation and provide the underlying data on request. You may dispute the decision through our complaints procedure.

You may close your account at any time by closing all open positions, withdrawing your balance and notifying us in writing. We may terminate this Agreement on 30 days’ written notice without giving reasons, or immediately where you are in material breach, where we are required to do so by law or by a regulator, where you become insolvent, or where we reasonably suspect fraud or market abuse.

On termination, open positions are closed at the prevailing market price, outstanding charges are settled, and any remaining balance is returned to you by an approved payment method within ten business days, subject to any legal or regulatory hold. Termination does not affect accrued rights or liabilities.

We are liable to you for losses caused by our own negligence, fraud or wilful default, and nothing in this Agreement limits any liability that cannot lawfully be limited. Subject to that, we are not liable for indirect or consequential loss, loss of profit, or loss arising from your reliance on our platform for a purpose for which it is not designed.

We are not liable for a failure to perform our obligations to the extent caused by an event beyond our reasonable control, including the suspension or closure of an underlying market, the failure of a liquidity provider, a failure of telecommunications or power infrastructure, a cyber attack, an act of a government or regulator, industrial action, or a natural disaster. Where such an event occurs we may suspend trading, widen spreads, increase margin requirements, or close positions at the last available price.

You indemnify us against costs, claims and liabilities we reasonably incur as a direct result of your breach of this Agreement, other than where they arise from our own negligence, fraud or wilful default.

If you were introduced to us by an introducing broker or affiliate, that partner is an independent contractor and is not our agent, employee or representative. They have no authority to make representations on our behalf, to advise you, to accept money from you, or to operate your account. Any advice, signal service or managed-account arrangement you enter into with a partner is a matter between you and them.

We pay partners commission based on the trading activity of the clients they introduce. That commission is paid out of the spread and commission we already charge you — it does not increase your cost of trading — but you should be aware that a partner has a commercial interest in your trading volume. The commission structure applicable to your introducer is disclosed to you on request.

Partners are bound by a separate partner agreement which prohibits misleading marketing, guarantees of profit, unsolicited contact, and any representation that trading CFDs is low risk. Breach of those terms results in termination of the partnership and forfeiture of unpaid commission.

If something has gone wrong, tell us. Complaints should be sent to compliance@apex.markets with your account number, the date and time of the events, the instrument and ticket numbers concerned, and what outcome you are seeking.

1. (a)We acknowledge every complaint in writing within five business days of receipt.
2. (b)We investigate independently of the desk concerned; the compliance function reports to the board rather than to revenue.
3. (c)We provide a final response within eight weeks, setting out our conclusion, the evidence relied upon and, where we have got it wrong, the remedy.
4. (d)If you are dissatisfied with our final response, or if eight weeks pass without one, you may refer the matter to the financial ombudsman or dispute-resolution body in our jurisdiction. We will give you their contact details with our response.

Making a complaint costs you nothing and does not affect your ability to trade or to withdraw.

We may amend this Agreement by giving you at least ten business days’ written notice, except where a change is required immediately by law or regulation, is to your advantage, or reflects a change in market conditions outside our control. If you do not accept an amendment you may close your account without charge before it takes effect; continuing to trade after that date constitutes acceptance.

You may not assign your rights under this Agreement. We may assign ours to an affiliate or successor on notice to you, provided your rights are not materially prejudiced.

This Agreement is governed by the laws of the Republic of Cyprus, and the courts of the Republic of Cyprus have exclusive jurisdiction over any dispute arising out of it, save that we may bring proceedings in the courts of your place of residence where required by law.