Ex-Post Costs and Charges Statements: What UK Advisers Must Show Each Year
Published by 
Steffan Kharmaaiarvi, founder
Every year an adviser with ongoing clients owes each of them an ex-post costs and charges statement: what the service and the investments actually cost over the year, in pounds and as a percentage, with the effect on return. This note sets out where the rule sits now that the UK has moved MiFID's Article 50 into the FCA Handbook, what has to be aggregated, how to treat actual and estimated figures, and a worked example.
Where the rule sits
In the EU the requirement is Article 50(9) of Delegated Regulation (EU) 2017/565: annual ex-post information about all costs and charges related to both the financial instruments and the investment and ancillary services, where the firm recommended or marketed the instruments or provided the KID or KIID and has or had an ongoing relationship with the client during the year, based on costs incurred and provided on a personalised basis.
In the UK, the UK version of that Regulation no longer has effect: legislation.gov.uk records its revocation, in so far as not already in force, from 23 October 2025. The requirement now sits in the FCA Handbook at COBS 6.1ZA.14BR, whose version in force is dated 6 April 2026. The Handbook notes that paragraph (1)(b) corresponds to what were the ex-post requirements under Article 50. For portfolio management, the periodic statement under COBS 16A.4.1R must also give the total fees and charges for the period, itemising at least total management fees and total costs of execution.
When it applies
Under COBS 6.1ZA.14BR(1)(b), where a firm provides the client with a relevant service on an ongoing basis in respect of a financial instrument the firm sold to the client or arranged for the client to buy, it must disclose on a personalised and annual basis the actually incurred costs and charges of the service and of the investment. For a retail client a relevant service is any service involving a regulated or ancillary activity (paragraph (2)). The disclosure may be given together with existing periodic reporting, must come with an illustration of the cumulative effect of costs on return, and does not apply to eligible counterparties.
What must be aggregated
Paragraph (3) requires the firm to aggregate the costs in COBS 6 Annex 7 for the services, including its own charges, and for the manufacture and distribution of the instrument. The Annex has two tables:
- Service costs. One-off charges (such as deposit, termination and switching fees), ongoing charges for the service, transaction costs (broker commissions, entry and exit charges, platform fees, mark-ups, stamp duty, transaction tax and foreign exchange costs), ancillary costs (research, custody) and incidental costs (performance fees).
- Product costs. One-off charges (front-loaded management or distribution fees), ongoing charges deducted from the instrument (management fees, service costs, swap fees, securities lending costs and taxes, financing costs), transaction costs inside the fund (commissions, entry and exit charges paid by the fund, mark-ups, stamp duty, transaction tax, foreign exchange) and incidental costs (performance fees).
For a consumer composite investment, the product figures in the ex-post statement are the actual ongoing costs, one-off costs, transaction costs and any performance fees or carried interest ((3)(b)). The total must be shown as a cash amount and as a percentage ((3)(d)), and third-party payments the firm receives in connection with the service must be itemised and disclosed separately ((3)(c)). Where more than one firm provides a service, each discloses its own costs, and a firm that directs the client to another firm's service aggregates both (paragraph (4)).
Actual, entered or estimated
The statement is about costs incurred, but the figures come from different places. Dealing costs are on contract notes and transaction records. Advice and platform fees are on invoices or the platform's own statement. Fund charges and fund transaction costs come from the fund manager's cost data. Some of these an adviser holds as exact amounts; others are a rate applied to an average value. A statement that labels each line by its source, and that does not quietly show a missing line as zero, is easier to explain to a client and to a file reviewer.
A worked example (illustrative)
A client's portfolio averaged £400,000 over calendar year 2025. Advice and platform fees are taken from the portfolio. No third-party payments were received.
| Line | Basis | £ | % of average |
|---|---|---|---|
| Ongoing advice fee | Entered from the firm's invoices | 2,000 | 0.50% |
| Platform and custody | Estimate: fee schedule 0.25% × £400,000 | 1,000 | 0.25% |
| Fund ongoing charges | Estimate: weighted 0.12% × £400,000 | 480 | 0.12% |
| Fund transaction costs | Entered rate 0.05% from the funds' cost data × £400,000 | 200 | 0.05% |
| Commissions and dealing | Actual, from the year's transactions | 64 | 0.02% |
| Total | 3,744 | 0.94% | |
| Third-party payments received | Entered; disclosed apart | 0 | — |
£3,744 ÷ £400,000 = 0.936%, shown as 0.94%. If the measured time-weighted return for the year was 7.10%, all costs are already inside it, and the return before costs is approximately 7.10% + 0.94% = 8.04%. Had the platform line been neither entered nor covered by a fee schedule, the honest total would be "not known" until it is completed, not £2,744.
What Borderfolio shows
- An annual statement per client. For a calendar year, or the current year so far, on the client's overview.
- Provenance per line. Dealing costs are actual, from confirmed transactions; advice and platform fees are your entered figures for the year, otherwise the fee schedule on the year's average value as an estimate; fund ongoing charges are today's weighted expense ratios on the average value (an estimate); fund transaction costs count only when you enter the rate from the funds' cost data, otherwise the line reads not included and is listed.
- No total while a line is missing. An unknown line withholds the totals and says what to complete. Third-party payments read "not entered" until you enter a figure, 0 included, and stay outside the total.
- Effect on return. The period's time-weighted return with the cost percentages added or taken away, labelled approximate.
- A fixed document. Generating the statement stores a snapshot with its PDF, which does not change afterwards (costs statement documentation).
Not modelled: performance fees and other incidental costs; currency conversion inside broker prices when statements do not show it as a fee; assets outside brokerage accounts, such as pensions held elsewhere; holdings that changed during the year are approximated by today's expense ratios. Ex-ante disclosures are not produced, and whether the rule applies to your firm and service is for your compliance function.
Sources: FCA Handbook COBS 6.1ZA.14BR and COBS 6 Annex 7, COBS 16A.4, Delegated Regulation (EU) 2017/565, Art. 50, legislation.gov.uk, UK Art. 50 status.
Frequently asked questions
Where is the ex-post costs and charges rule for UK firms now?
In the FCA Handbook at COBS 6.1ZA.14BR(1)(b), which the FCA notes corresponds to the former ex-post requirements of Article 50 of the UK MiFID Org Regulation. The UK version of that Regulation no longer has effect.
When is an annual ex-post statement required?
Under COBS 6.1ZA.14BR(1)(b), where the firm provides the client with a relevant service on an ongoing basis in respect of a financial instrument it sold to the client or arranged for the client to buy.
Are third-party payments part of the total?
They must be itemised and disclosed separately (COBS 6.1ZA.14BR(3)(c)). Borderfolio shows them apart from the total.
Can the statement be combined with periodic reporting?
Yes. The rule allows the firm to provide the disclosure together with any existing periodic reporting to the client.