Who gets paid while you trade?

People who send clients to a broker are paid per new depositor, per trade or lot, or as a share of revenue. Separately, regulators say that a broker which keeps its clients' risk unhedged makes money when those clients lose, and that paying referrers on client volume is a conflict of interest to be managed or avoided. This note sets out what the documents say, and where they stop.

How introducers are paid

Brokers' own partner pages and affiliate agreements describe three models:

• A one-off amount per new client (cost per acquisition, CPA): paid once for each referred client who meets the broker's qualifying conditions.
• A commission or rebate on every trade or lot the referred client makes.
• A share of revenue from the referred client.

Some brokers offer combinations. None of the partner pages I could open published amounts. Where a broker's agreement defines the revenue that is shared, it is the broker's spread income minus costs. Another broker advertises "up to 40% of revenue from referred clients' trades" without defining revenue. I found no broker document that defines a revenue share as a share of client losses.

How common volume-based pay is, in one market where a regulator counted: in 2019, Australia's ASIC found that 92% of referral arrangements paid referrers based on client trading volumes, and that in 2018 issuers paid over A$281 million to referrers. ASIC also reported clients being approached by referrers "in chat rooms, dating sites, through mainstream social media and taxi cabs".

How brokers earn from retail flow

ESMA's questions and answers on CFDs describe three ways a broker can run its book:

1. hedge every client order with another party;
2. deal as the client's counterparty without hedging;
3. hedge some of the risk and keep the rest.

A fully hedged firm, ESMA writes, "can make a profit regardless of whether CFDs or other speculative products sold to their retail clients are profitable or not". For a firm that is the client's counterparty without hedging, it writes that the firm "cannot make money unless the client loses money", and that such a conflict "in all likelihood cannot be managed and should therefore be avoided, by not adopting such a business model".

The UK's FCA, in a 2022 letter to CFD firms, put it this way: "Where the market risk from firms' customer activity is under-hedged, firms also directly profit from customer losses, further incentivising them to encourage excessive customer trading."

ASIC attributes Australian CFD issuers' revenue largely to "a combination of net client trading losses and spreads, fees and commissions charged to clients". In October 2026 it reported retail CFD losses exceeding A$458 million over 12 months.

Brokers' own execution and conflicts documents show the models in practice. One states that it is the counterparty to its clients' trades and acts as principal. One parent company describes managing its exposure "by aggregating its exposure and internally offsetting client trades". One acts as principal and may hedge or offset risk internally. One hedges all client trades with its parent and may pay or receive referral fees. These are the firms' descriptions of themselves; none of them says how much any firm earns from client losses, and this note does not either.

What regulators say about paid introducers

• FCA (UK, 2022): "many firms use unauthorised affiliates to introduce clients, paying them for their introductions". "Many are social media 'influencers' who target younger consumers with lower levels of financial literacy for whom CFDs are inappropriate." Some "market themselves as FX 'educators' and 'signals providers'".
• FCA (UK, 2024): affiliate marketing means paying commission "based on business generated from referrals", and an affiliate earning commissions "may need to consider whether that activity involves them carrying on regulated arranging activity".
• ESMA (EU, 2017): an education provider paid by a broker "based on the volume of clients who received the online training and who subsequently trade CFDs" is given as an example of a conflict to be managed or avoided.
• CySEC (Cyprus, 2017): firms are encouraged to market in-house or to cooperate "with the absolute minimum number of Affiliates".
• ASIC (Australia): an influencer who receives payment for comments on financial products is "more likely to be providing financial product advice".

Turkey

Onshore leverage for retail clients is capped at 10:1 when a position opens (2017). In a February 2023 statement, the Capital Markets Board (SPK) said that offering leveraged trades to residents of Turkey by anyone it has not authorised is the crime of unauthorised capital-markets activity, punishable by two to five years in prison, and that it files criminal complaints against those who make that activity easier, including by promoting or advertising it. Under the 2013 rules, where an authorised firm takes the other side of a client's trade and the client's loss is the firm's profit, that conflict has to be stated separately in the risk disclosure form. I did not find a current Turkish rule specifically on paid introducers, and I did not check later amendments to these texts.

Two facts, not one

An introducer paid per trade or per lot earns from the referred client's trading volume, whatever the client's result. And regulators say that a broker which leaves client risk unhedged earns when the client loses. Those are two separate facts. No document I found shows an introducer's revenue share being paid out of client losses, so this note does not claim it.

Sources: ESMA Q&A on CFDs and other speculative products (ESMA35-36-794, March 2017 version); FCA portfolio letter to CFD firms (December 2022); FCA FG24/1 (2024); ASIC Consultation Paper 322 (2019), INFO 269 and media release 26-239MR (2026); CySEC Circular C217 (2017); SPK press release of 23 February 2023 and Communiqués III-37.1 and III-39.1. Broker partner and policy documents accessed 12 November 2026; list available on request. Every quotation was checked word for word against the source.