Trading 212 UK Limited · DRN-5810616

The complaint Mr T complains that he did not receive interest on the uninvested cash he held in a stocks and shares ISA with Trading 212 UK Limited (‘Trading 212’). What happened Mr T opened a stocks and shares ISA with Trading 212 in April 2024. He deposited £20,000, but didn’t invest this as he was waiting for the right opportunity and was happy in the meantime with the interest he expected to earn on the uninvested cash. In July 2025, Mr T contacted Trading 212 as he had noticed no interest was showing in his account. His expectation was that it would be updated at least annually, so he queried this. Trading 212 explained that interest needed to have been ‘enabled’ in order for it to be paid on uninvested cash. Mr T was unhappy with this explanation, as it was not something he had experience of and he had no recollection of being told about it when opening the account. Mr T brought his complaint to our service, but an investigator did not think it should be upheld. As Mr T disagreed, the complaint has been passed to me. What I’ve decided – and why I’ve considered all the available evidence and arguments to decide what’s fair and reasonable in the circumstances of this complaint. Mr T is unhappy that he had to effectively ‘sign up’ for interest to be earned on his uninvested cash by clicking an ‘enable’ button. He says this isn’t something he’s ever had to do in order to earn interest before. I’ve considered whether this was something Trading 212 was allowed to require of him, and whether it was fair and reasonable of them to do so. The interest rate that Trading 212 was offering on uninvested cash held in the stocks & shares ISA was not the same as interest accrued in a typical bank account. Instead, it was generated by investing the uninvested cash into Qualifying Money Market Funds (‘QMMFs’). By investing the cash held in the stocks & shares ISA, a return is generated and paid back to the consumer as ‘interest’. This is all set out in the ‘Invest Terms’ – the terms and conditions of the account, which Mr T would have had to agree to when he opened the ISA. Specifically, Section 15 of the terms states: “15.1. If you provide us with your express consent to participate in our Interest Sharing Programme, in addition to Regular Bank Deposits and Term Deposits, we may hold your Available Cash in a QMMF. 15.2. At any time, you can change your mind and either opt in or out of the Interest Sharing Programme via our Website. If you choose not to participate in the Interest Sharing Programme, we will not hold your Uninvested Money in QMMFs and therefore, no interest will be paid to you as per clause 15.1.

-- 1 of 2 --

We may still hold your Uninvested Money in Term Deposits and/or Regular Bank Deposits with EU/UK-regulated financial institutions, and we will retain any received interest.” Additionally, the ‘Interest on Cash’ section on Trading 212’s platform states “If you enable interest, we will hold your cash in qualifying money market funds and banks. Otherwise, we will hold it only in banks. Interest applies on cash in an investment account. Terms apply. When investing, your capital is at risk.” Although relatively low risk, cash invested in QMMFs would still be considered to be an investment, where the capital is at risk, rather than a cash deposit. And QMMFs are generally not covered by the Financial Services Compensation Scheme. As such, it would have been wrong for Trading 212 to automatically invest a consumer’s uninvested cash into QMMFs in order to generate a return. To have done so, Trading 212 would have needed the relevant regulatory permissions to invest on Mr T’s behalf on a discretionary basis, and they would also have had to consider the suitability of the investment for him. Neither of these occurred here. So overall, I’m satisfied it is correct for there to be a requirement that a consumer opts in to this, given it is a form of investing. I acknowledge Mr T’s point that the advert he saw did not explain the detail about having to opt in. However, I don’t think it’s reasonable to expect marketing material of that kind to include the full details of what was on offer. It is reasonable to expect consumers will rely on additional sources of information, not just an advert, before taking out an investment product, and it reasonable for the advert to be brief, as long as it is not misleading – and I do not think it is, in this case. I can see that there is a ‘learn more’ link on the advert, and I’m satisfied that both Trading 212’s website and terms and conditions set out the details clearly. So overall I don’t consider that Trading 212 needed to do more to bring the ‘opt in’ requirement to Mr T’s attention within the advert itself. Mr T is also unhappy that he missed out on such a long period of interest, and that he received email updates when the interest rate changed, leading him to believe he was benefitting from this. I appreciate Mr T’s frustration and his explanation that he thought it may take up to a year for interest to show on his account. But the advert says that interest is paid daily, and this information was available to view on the app, website or monthly statements. Receiving a generic email notifying of changes to an interest rate cannot be taken as confirmation that you are eligible or receiving that rate. It is unfortunate for Mr T that he did not query the lack of interest payment earlier, but I can’t say Trading 212 have done anything wrong in this regard. My final decision I do not uphold this complaint. Under the rules of the Financial Ombudsman Service, I’m required to ask Mr T to accept or reject my decision before 17 April 2026. Artemis Pantelides Ombudsman

-- 2 of 2 --