COBS 11 — Dealing and managing

Category: Compliance & AML · Reviewed by Taylor Watts, Broker · New Business · Last reviewed June 2026

The FCA rules governing how firms execute orders for clients, including best execution, order handling, client order priority, and the recording of telephone conversations and electronic communications relating to trades.

Definition

COBS 11 (and the MiFID-derived COBS 11A) sets the rules on dealing and managing for designated investment business. It covers the best execution duty, client order handling, aggregation and allocation, the duty to manage conflicts in execution, recording of telephone and electronic communications relating to client orders, and the obligation to obtain the best possible result for the client.

Legal / Regulatory basis

FCA Handbook, COBS 11 and COBS 11A. Made under FSMA sections 137A and 138, implementing UK retained MiFID II Article 27 (best execution) and Article 16(7) (call recording).

How it works in practice

Best execution requires firms to consider price, costs, speed, likelihood of execution and settlement, size, nature and any other relevant consideration when executing client orders. The firm must establish an execution policy, monitor the quality of execution, and disclose execution information to clients. Phone calls and electronic communications relating to orders must be recorded and retained for five to seven years.

Common variations

For pure insurance intermediation the COBS 11 dealing-and-managing regime does not apply — placement of insurance is not “execution” in the COBS sense. Best execution principles do however inform the wider Consumer Duty fair-value assessment.

Example

A wealth manager placing an equity trade for a client must demonstrate compliance with COBS 11A best execution policy. An insurance broker placing a commercial property risk is outside this regime.

See also

• COBS — Conduct of Business Sourcebook
• COBS 16 — Reporting to clients
• ICOBS 5 — Identifying client needs and advising

References

FCA Handbook, COBS 11 and COBS 11A. Financial Services and Markets Act 2000, sections 137A and 138. UK retained MiFID II (Directive 2014/65/EU), Articles 16(7) and 27. Commission Delegated Regulation (EU) 2017/565, Articles 64–66.

Last reviewed

By Matt Bartlett, Director, on 2026-06-11.

This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.