Project Overview
A UK FCA-authorised equity crowdfunding platform wanted to rebuild their legacy platform (2013 codebase, jQuer...
Technology Stack
Compliance & Standards
The Challenge
A UK FCA-authorised equity crowdfunding platform wanted to rebuild their legacy platform (2013 codebase, jQuery, no mobile experience) with a modern React/TypeScript architecture. FCA COBS 14 (appropriateness assessment for retail investors in non-readily realisable securities), FCA COBS 4 (financial promotions), FCA Consumer Duty PS22/9, UK GDPR for investor personal data, and Companies House API for company verification were the requirements. Budget: £120,000.
Our Approach
FCA Appropriateness Assessment
COBS 14.3A.8: retail investors in non-readily realisable securities (unlisted equity) must pass an appropriateness assessment.
Assessment engine
8-question knowledge test (understanding of investment risk, illiquidity, dilution, EIS/SEIS tax reliefs).
Scoring
- pass (7/8 correct) → full access, refer (5–6/8) → additional risk warning + cooling-off, fail (<
- 5/8) → cannot invest (exception: sophisticated investor self-certification or high net worth declaration).
Elective professional investor
separate declaration process.
COBS 4
- all financial promotions must be fair, clear, and not misleading.
- Crowdfunding pitches are financial promotions.
Promotion approval workflow
company pitch → ClickMasters FCA compliance review → approved version stored with version hash → approved version only displayed to investors.
Pitch changes
any material change requires re-approval.
Risk warnings
- FCA-mandated risk disclosure on every pitch page ("Your capital is at risk.
- This type of investment is not suitable for most retail investors.").
EIS/SEIS Integration
Enterprise Investment Scheme (EIS) and Seed Enterprise Investment Scheme (SEIS): companies with advance assurance from HMRC SEIS/EIS team are flagged.
HMRC EIS compliance check API
verify advance assurance reference.
SEIS/EIS certificate generation
after investment completion, SEIS3/EIS3 certificate generated for investor (enables 50%/30% income tax relief claim).
Investor tax relief dashboard
tracks each investor's SEIS/EIS certificate status per investment.
Companies House API
company registration verification, director check (no disqualified directors), filing history review (accounts filed, confirmation statement current), SIC code (sector check — some sectors ineligible for SEIS/EIS), and PSC register (beneficial ownership).
Automated due diligence report
generated at campaign approval — PDF attached to campaign record.
Money laundering check
Experian commercial check + director KYC (Onfido).
The Results
Platform live at 18 weeks, £112,000 — under budget.
Mobile conversion rate: 4% (legacy) → 31% (new platform).
Appropriateness assessment failure rate: 34% (correctly filtering inappropriate retail investors).
FCA financial promotion review: zero promotions rejected post-approval (legacy: 12 post-approval FCA queries in prior year).
EIS/SEIS certificate generation: automated — previously 2 weeks manual.
Campaigns funded: £8.4M in first 6 months on new platform.
“Mobile conversion from 4% to 31% — the legacy platform was losing investors before they could invest. £8.4M funded in 6 months. Zero post-approval FCA queries on financial promotions — the approval workflow eliminated the category of error. EIS certificate automation saving 2 weeks per campaign." — CEO, UK Equity Crowdfunding Platform (name withheld)”
Project Details
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