In force from 2020-07-03

CFD Trading

These Terms & Conditions apply to CFD Trading service and your Margin Account. Please read them carefully. You can access and download a copy of these Terms & Conditions at any time from

These are specific terms that will apply to you when you trade CFDs directly with Indexa B.V. using Change Apps. The following terms apply to you in addition but not limited to the chapter General and Wallet, which apply to all of our services and not just to CFD Trading. Capitalised words have the same meaning which are given to those words in the General and Wallet chapter or in any other chapter in this regard. In the event of any discrepancies between the terms of CFD Trading and General and Wallet or other terms of Change, these terms of CFD Trading chapter shall prevail.

In these Terms & Conditions:

  • “Apps” mean the web, Android and iOS mobile apps of Change, which give access to the Services;
  • “Change” means third party xChange AS, an Estonian public limited company registered under registry code 14428150, Rävala pst 4, 10143 Tallinn to whom Indexa B.V. relies on to comply with requirements included in the Dutch Wet ter voorkoming van witwassen en financieren van terrorisme and the Santiewet 1977, namely the application of due diligence measures, identification of politically exposed persons and customer data retention;
  • “You” means the named account holder being the authorised user of CFD Trading and owner of the Margin Account and Open CFD Positions;
  • “We”, “us” or “our” means Indexa B.V. (Chamber of Commerce no. 50755854, previously B.V.), De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands, who provides CFD Trading service on a cross-border basis and is authorised and regulated by the Dutch Authority for the Financial Markets (AFM).

If you have any questions you can contact us by:

All of the terms and definitions not stipulated in these Terms & Conditions are stipulated in the General and Wallet chapter.

1. What is CFD trading and how it works?

1.1. A contract for difference (“CFD”) is a financial product which allows you to trade on the price movements of an underlying product for example shares, forex, indices, commodities, or cryptoassets. When you trade a CFD, you are agreeing to exchange the difference in the price of an underlying product from the point in time when your position is opened to when it is closed.

1.2. We may act as principal or on a matched principal basis when providing you with the CFD Trading Services. This means we will be the counterparty to your trades.

1.3. Where you buy and sell complex products, such as CFDs, we are required to assess the appropriateness of the product by taking into account your trading knowledge and experience by conducting the Appropriateness Assessment.

1.4. If we have assessed that the CFD Trading is not appropriate for you, we will either:

1.4.1. provide you with an appropriate warning, after which you may decide to continue at your own risk; or

1.4.2. refrain from enabling the CFD Trading functionality on your Account, so that you will not be able to trade using the Apps.

1.5. We allow you to trade CFDs using Margin Trading. This means you can make money quickly, but you can also lose money quickly. You can find out more about what Margin Trading and leverage are, the risks of trading CFDs, and the risks of leverage in section 3 and 5, the General Risk Disclosure, and on Website.

1.6. If you are a retail client, we will make sure that your Open CFD Position will get closed when the unrealised net profit of that Open CFD Position falls to less than half of the initial margin.

1.7. If you are a retail client, we will make sure you do not lose more money than what you have deposited on your Margin Account.

2. What are the limitations to CFD Trading?

2.1. When you trade a CFD, you will have an economic exposure to the underlying product of the CFD, but you will not have legal ownership of any underlying products. For example, if you trade a CFD over shares, you will not have the rights which legal owners have, such as voting rights or rights to dividends. However, we may carry out adjustments if such a Market Event occurs. Please refer to section 13 of these terms for more information on a Market Event.

3. What are the key risks of CFD Trading?

3.1. CFDs are complex derivative products and come with a high risk of losing money quickly due to leverage. Trading with leverage magnifies your gains and losses, so small price changes in the underlying product can result in large losses or gains. It is therefore possible that you may lose more than your deposit in a specific trade. Please refer to section 5 of these terms for more information on Margin Trading.

3.2. The underlying assets of CFDs are often made up of equities, foreign exchange, commodities, cryptoassets and similar products. The markets of these products can be volatile, which means the prices of the products can change rapidly, and therefore may be unpredictable.

3.3. You should only trade CFDs if all of the following applies:

3.3.1. you have sufficient and relevant knowledge about or experience in, trading in volatile markets;

3.3.2. you have time to manage your Open CFD Positions on an active basis;

3.3.3. you fully understand how CFDs work (including all associated risks and costs), are aware that Margin Trading creates greater risks;

3.3.4. you understand that there are situations where we are allowed to close out your Open CFD Positions without giving you any notice;

3.3.5. you are trading with money you can afford to lose;

3.3.6. you have a high-risk tolerance; and 

3.3.7. you want to gain short term financial exposure to a product.

3.4. You should ensure you fully understand the risks involved before using our Services and, if required, take appropriate investment, financial, legal, tax and other necessary professional, independent advice. More information on the risks associated with trading CFDs is set out in our General Risk Disclosure. You should read this document and fully understand the risks before accepting these Terms & Conditions.

4. How is your money protected?

4.1. Money that you have transferred to your Margin Account, i.e. the deposit is held by an independent foundation named Stichting Cliëntengelden Optionclub which keeps liquid assets equal to all balances of Margin Accounts + an extra 10%. This means it is always guaranteed that all balances of Margin Accounts can be paid out.

4.2. We are covered by the Dutch investor compensation scheme (ICS) operated by the Dutch central bank. If we fail, the scheme guarantees that you will receive back your money deposited on the Margin Account up to € 20,000 or as may be updated from time to time.

4.3. Importantly, the protection is only applicable to regulated products i.e. CFD Trading. This means that any cryptoasset related Service is not protected.

4.4. Claims ensuing from investment losses suffered from CFD Trading are not eligible for compensation.

5. How Margin Trading works?

5.1. We allow you to trade CFDs using leverage. Leverage is a form of borrowing which allows you to deposit only a part of the cost of your transaction upfront. This deposit is called “margin” and is used by us as security against any potential losses you may incur. The more leverage you use, the less margin you need. Money being used as margin cannot be transferred out of your Margin Account.

5.2. Different amounts of leverage, i.e. margin requirements apply to different underlying products. Applicable law sets maximum leverage amounts, but we can decrease the leverage we offer at any time. The amount of leverage which you can access at a particular point in time can be viewed on the Website or in the Apps.

5.3. If you are a retail client, we are required by law to limit the amount of leverage that you can apply to certain transactions and set a minimum margin requirement. Professional clients will not be subject to these restrictions. The nature of these restrictions will depend on where you are a resident, and are likely to vary depending on the underlying product that you are trading. Where transactions were executed with a leverage or margin that is no longer permitted in the country where you live, we may close any or all of your Open CFD Positions without further notice to you and we may also close your Account. You acknowledge that this may result in a profit or a loss to you.

5.4. We will calculate your margin on a position by position basis. The money available as margin on a position, cannot equal less than 50% of the money that you might lose on that Open CFD Position at any time. If you do not have enough margin available, we may require additional margin to secure your trades. The amount of money that you must have available as a margin can be viewed on the Website or in the Apps.

5.5. It is your responsibility to monitor the money in your Margin Account against your potential losses, the margin required, and whether your position is close to your stop level, as we will not notify you when this happens. If you do not have enough money in your Margin Account to meet the margin requirement on a certain position, you should do the following:

5.5.1. close any or all of your Open CFD Positions to stop losing more money;

5.5.2. partially close any or all of your Open CFD Positions; and/or

5.5.3. adjust your stop levels, but please note, that the ability to adjust your stop levels is subject to you having the appropriate amount of money on your Margin Account.

5.6. Unless you carry out one or more of the steps listed in clause 5.5, your Open CFD Position will be closed irrespective of the total amount of money available on your Margin Account or the performance and balance of your other Open CFD Positions.

5.7. We may change our margin requirements i.e. leverage multipliers at any time, at our sole discretion, including in order to comply with the applicable law. One margin demand does not preclude another. Any amount needed to meet the new requirements must be satisfied in the currency we specify. The adjustment should be made immediately unless we specify a future date and/or time by which the adjustment must be made.

6. How can you place an order?

6.1. An order is any instruction given or request placed by you with us to purchase or to sell or otherwise deal in financial products, which may include a limit order, stop loss order and/or take profit order or such other order as may be available on the trading platform from time to time. We will then need to accept your order for it to take effect. Please read section 7 which explains when you might be able to change or cancel your order, as well as when we might not accept your order or cancel your order when using CFD Trading Service.

6.2. You can place an order by using the Apps. Generally we do not accept orders over the phone, but may do so at our discretion.

6.3. We will execute orders that are received from your Account, and which we reasonably believe are from you, or authorised by you. Please be careful when placing an order. If you place orders by accident or in error, for example if you place multiple orders which are the same, we will assume that you did this on purpose and we will execute them without checking this with you.

6.4. Once we accept your order, we will execute it in accordance with any specific instructions that you give. This is called a trade. For more information on how you can place an order, the instructions that you can give, and how we may execute your order, please read our Best Execution and Order Handling Policy.

6.5. We cannot guarantee that your execution price will match your order price, including where you've placed a limit order, take profit and/or stop loss order. This is because the market may be volatile and/or the price may have moved up or down between the time that you place your order (or the time your limit order, take profit and/or stop loss order has been activated) and the time that we execute your order. This is known as slippage. When this happens, we will execute your order at the next best price and in accordance with our Best Execution and Order Handling Policy.

6.6. If you have placed an order during the condition stipulated in the following sub-clauses then the applicable order you have placed will be executed as soon as is reasonable under the circumstances when trading resumes. We do not guarantee that your order will be executed at the first available underlying market price at commencement of trading or within any specific range compared to other market prices which may be available to you from other sources. We are not liable for any loss or for other claims which you may have in connection with such orders. The conditions can be the following:

6.6.1. times in which the market of the underlying is suspended (for example, during the weekend or at off-market hours, suspension due to market conditions or due to any other event in which the market of the underlying is suspended); and/or

6.6.2. during the time the market was open, however, your order is triggered shortly following a suspension.

6.7. We will execute orders received during trading hours. Different products have different trading hours and these are available on the Website. It is your responsibility to ensure you are aware of the trading hours for the product you are trading. We may agree to execute orders outside of business hours, at our discretion.

6.8. Where you place an order outside of market hours, or where the product you are trading has a 24/7 market, but your order is placed during a period where there is limited trading (for example during the weekend), the availability of the different functionalities which we may provide as part of CFD Trading, including instructions which you may give in respect of a trade, may be delayed or may not be available. We are not liable for any loss which results from your inability to access or provide certain trading functionalities and instructions.

7. How can you manage your placed order?

7.1. You may request to cancel or modify an order which we have not executed. However, we cannot guarantee that we will be able to carry out your request. This will depend on the product that you are trading.

8. In what circumstances we may not accept an order?

8.1. We are not required to accept every order that you place and have reserved the right to decline any order or transaction. Even if we have accepted your order we are not required to execute it. The following is a non-exhaustive list of examples of situations where we may not accept an order, not execute or complete an order, or cancel an order:

8.1.1. we reasonably believe that the security of the App or your Account, including Margin Account is at risk, or if we're concerned about unauthorised or fraudulent use of your Account. This might happen if we think someone is using your Account without your permission;

8.1.2. you do not have enough money in your Margin Account to cover the maximum amount of loss associated with your order, plus any associated fees, charges and applicable margin;

8.1.3. we have a good reason to believe that there is an error with your order. For example, if you have placed an order that is unusually large and you have never done this before;

8.1.4. the order you have requested is unusual or for exaggerated volumes;

8.1.5. there is an error with the quote that we have provided. For example, if the quote is manifestly different from the market price, prices on exchanges, prices on other trading platforms, and/or if the quote lacks economical sense;

8.1.6. there is a change in the applicable law, which means that the order is no longer in compliance with the law;

8.1.7. there is a Market Event;

8.1.8. an exchange requests or recommends that the order is cancelled;

8.1.9. you breach the rules of trading;

8.1.10. an event of default occurs; or

8.1.11. an exceptional event occurs.

8.2. If we do not accept your order, execute your order, or cancel your order, we will inform you by making that information available in the Apps, unless there is a legal reason that we cannot provide this information to you. If we charged you a fee as part of the order, we will refund that money back into your Margin Account. If there were no fees or charges, then you will not receive a refund.

8.3. If we have executed your order, and therefore a transaction has occurred, we may take corrective actions and either modify the transaction, or void the transaction, under the scenarios listed in clause 8.1 above. We will inform you of errors by making information available on our trading platform, including any corrective actions we intend to take.

8.4. We will not be responsible for any losses you incur as a result of any actions or inactions taken by us in accordance with this section 8.

9. On what terms will my trades execute?

9.1. We are required to take sufficient steps to achieve the best possible result for you, on a consistent basis, when providing CFD Trading. Our Best Execution and Order Handling Policy sets out the procedures that we follow as well as the relevant market factors that we take into account as part of our best execution obligation. This policy, which may be amended from time to time, forms part of our agreement with you and is available on our website.

9.2. We understand that the best execution result is one that produces the best possible financial result for you, and that the “best possible financial result” is the best possible result in combination across all your trades. This means that some trades, taken individually, may be less favourable. Where we reasonably believe that it is in the overall best interest of all our clients, we may combine your order with our own orders or those of other customers, or we may split your orders. Best interests are not solely determined by price, and we also consider other factors, such as the speed of the trade and the likelihood of the trade being successful, to be important. Aggregation or splitting of orders may result in you obtaining, on some occasions, more favourable terms or price, and, on other occasions, less favourable terms or price than if your order had been executed separately.

9.3. We monitor the effectiveness of our Best Execution and Order Handling Policy on a regular basis to ensure that we consistently achieve the best results for you.

10. When can your Open CFD Positions get automatically closed?

10.1. We may close your Open CFD Position where our system or you have placed a stop-loss order and the stop price has been reached.

10.2. We may decline or cancel your order and close your Open CFD Position where you do not have the required margin in your Margin Account or you do not meet the margin requirements, as described in section 5 above. We may do this without further notice to you, and you may make a profit or a loss as a result.

10.3. We may also close your orders in special circumstances or when a Market Event occurs as described in section 13 below.

10.4. Please refer to section 8 above for more information about our rights and your rights in special circumstances.

11. How can you see your orders and trades?

11.1. Information about your trading activities, which includes records of the trades that you've concluded, your Open CFD Positions, margin, balances as well as other information about your trades and orders, is available online in your Account. Your Account will be updated no later than 24 hours after any activity takes place. You will be able to filter this information in different ways, for example on a per month basis. We are under no obligation to provide this information in hard copy or by email, but we may do so upon your request.

11.2. If you think there is a problem with your Account, please contact us as soon as possible and not later than 48 hours following the day on which the information became available. Otherwise, the information will be conclusive evidence of your transactions, concluded trades, your Open CFD Positions, margin, and balances.

11.3. We are required to keep your records for at least five years after your Account is closed. This period may be extended by the applicable law or agreement between you and us in writing. These records will be our sole property.

12. What are the rules of trading?

12.1. There are rules which you need to follow when using our CFD Trading Service. These are:

12.1.1. you must not reverse engineer or avoid any security measures on the trading platform;

12.1.2. you must not use any software, artificial intelligence, ultra-high speed, or mass data entry which might manipulate, game, abuse, or give you an unfair advantage when using our systems or Services;

12.1.3. you will not enter into trades which manipulate our systems or Services, for example entering into a buy trade as well as a sell trade, for the same or for a similar product, at the same or similar time;

12.1.4. you will not enter into transactions or combinations of transactions such as holding long and short positions in the same or similar instruments at similar times either by you or by you acting in concert with others, which, taken together or separately, are for the purpose of manipulating our systems or Services for gain;

12.1.5. you will not act in an unfair, abusive, manipulative, or illegal way when using our Services, for example scalping;

12.1.6. you will not enter into trades aimed at exploiting errors in prices and/or conclude trades at off-market prices; and

12.1.7. your order must not violate exchange rules or securities or commodities laws, regulations or rules, and/or be intended to defraud or manipulate the market.

12.2. If you make money by breaching the above rules, we may not pay that money to you or, if we have paid that money, we may deduct it from any of the balances of your Account.

12.3. If you breach any of the above rules we will record such breach. We may also cancel your orders, freeze, block and/or terminate our Services, your Account, and/or our agreement with you. We may, but are not required to, give you notice of this, subject to the applicable law.

13. What are Market Events?

13.1. There are various types of events that affect the trading of specific products resulting in for example higher price volatility, higher trading activity or changes related to the structure of a given product. Most of the latter can be categorized as corporate events which will result in a change to the financial instruments. Examples of corporate events include share consolidations, share splits, reorganisations, mergers, take-over offers (and similar), name changes and rebranding, dividend distributions, and delistings.

13.2. If a Market Event impacts the underlying product of a CFD, we will use reasonable endeavours to adjust all Open CFD Positions on that instrument, in a fair way and in accordance with market practice, and/or taking into account the treatment we may receive from our counterparties or any relevant third party and the deduction of any taxes applicable. The adjustments we carry out will depend on the circumstances of each event, and is according to our sole discretion, however we are not obliged to do this. Adjustments may include changing the price or the quantity of CFDs that you have to reflect the economic rights that you had prior to the Market Event occurring.

13.3. If an issuer of an underlying product goes into insolvency or is dissolved, we will close any Open CFD Positions related to that product. The closing date shall be the date of insolvency. Any money from the sale will be paid into your Margin Account. If you lose money as a result of the sale, we are not responsible for this.

13.4. We reserve the rights to close out any Open CFD Positions at the market price immediately prior to the Market Event taking place.

14. What are the possible conflicts of interest?

14.1 We are required to act in your best interest when providing our Services. However, there may be instances where your interests conflict with our interests, or with another customer's interests. For example:

14.1.1. we may execute hedging transactions before or after entering into a transaction with you to manage our risk in relation to the transaction, which may impact the price you pay or receive for such transactions, and we will retain any profits generated by such hedging. However, we are not required to hedge transactions if we do not want to;

14.1.2. we may enter into arrangements with third parties, or with other customers, where we make payments to them or receive payments from them based on your trading activity or volume, where such arrangements are permitted by the applicable law. These payments may include rebates, commissions, widened spreads and profit sharing;

14.1.3. we may provide, pay or receive fees, commissions or non-monetary benefits where such payments are permitted by the applicable law; 

14.1.4. we may share dealing charges with our affiliate companies or receive remuneration from them in respect of transactions carried out on your behalf; 

14.1.5. we may be the counterparty to trades that you enter into; and

14.1.6. we are responsible for setting the price of instruments and products which can be traded in the Apps. This means that our prices can be different from the prices provided by other brokers and the market price, as well as the current prices on any exchanges or trading platforms.

14.2. We have in place a number of internal policies and arrangements to help manage any conflicts. In addition, the potential conflicts related to trading detailed above are subject to an objective criteria which is set out in our Best Execution and Order Handling Policy.

15. How we may contact you?

15.1. You expressly consent to us using the Apps or Website, as we deem appropriate, to inform you of information about us and of changes to such information (including changes to Terms and Conditions and our Best Execution and Order Handling Policy).

15.2. We may also communicate with you via Apps and Website, by email, telephone, post, newsletter, letter, electronic chats, and/or any other means of communication. We will use the contact details you gave us when you opened your Account, and as updated by you to us.

15.3. If your details change, including your email address, contact numbers, name, home address, country of residence or nationality, you must tell us as soon as possible. If you do not let us know, you might not receive important information from us.

15.4. Our Terms and Conditions, i.e. our agreement with you, and all information, statements and notifications between you and us, will be in English and we will communicate in English. If we provide you with documents in another language, and there is an inconsistency, the English version will prevail.

16. How can you make a complaint regarding CFD Trading?

16.1. If you are unhappy with a Service or something has gone wrong, please contact us so we can investigate the circumstances for you and we will try to put it right. You may contact us using any of the following means:

16.1.1. email to or;

16.1.2. log in to the App and send us a secure message; or

16.1.3. send a letter to De Hooge Krocht 2, 2201 TX Noordwijk, the Netherlands.

16.2. We will make every possible effort to address all points of complaint by email. We will respond within 5 business days upon receiving the complaint. If a full response cannot be provided within these timeframes, we will send a holding reply with a full response to follow within 20 business days.

16.3. If you want to know more about how we handle customer complaints, please read our Complaints Handling Procedure.

16.4. If you're still not happy with how we've dealt with your complaint, you can refer it to the Dutch Financial Services Complaints Tribunal (Kifid) using our registration number 400.000422. The Kifid consists of the Financial Services Ombudsman and the Financial Services Disputes Committee.

16.5. Ultimately you may turn to the Dutch Authority for the Financial Markets (AFM) or to relevant courts. For more information on such alternative solutions, please refer to the Website.

17. Will these terms ever change?

17.1. We may change these Terms & Conditions by notifying you by e-mail or other agreed means at least one month before the change is due to happen. We will assume that you agree with the change. If you do not agree with the change you must tell us before the change happens and we will cancel your account immediately. If your account is canceled or you cancel your account in this way, we will return any balance on the account to you.

17.2. An up-to-date version of these Terms & Conditions, as well as any notices of future changes will always be available on the Website. You should check it regularly for such notices and changes.

18. Can I assign my rights or obligations under these terms?

18.1. You may not transfer or assign any rights or obligations you may have under these Terms & Conditions to any other person without our prior written consent. We may assign the benefit and burden of these Terms & Conditions to any other person at any time on giving you two months prior notice of this. If we do this, your rights will not be affected.

19. What is the governing law?

19.1. This agreement is concluded in English. All communications with you will be in English. These Terms & Conditions are governed by Dutch law and all disputes shall be solved by a way of negotiations, or if the Parties fail to do so in respective Dutch courts.

20. What are the fees and limits?

20.1. We will charge you a fee for each order we execute for you. This is called a spread. A spread is the difference in the sell and the buy price. The spread is different for each type of product and Service and can be found in the Apps and on the Website.

20.2. We will estimate the total amount of spread that applies each time you place an order. We cannot provide you with an exact amount because the spread may change between the time you make an order, and the time we execute your order.

20.3. The spreads which we charge can change due to market conditions. For example, there may be instances when market conditions cause spreads to widen beyond the typical spreads displayed on our website and/or platform.

20.4. All the information is available in chapter Fees and Limits. However, for specific Services, other fees may also apply. For example, if you trade CFDs, we also charge you an overnight fee. We may update our commissions, charges, fees and costs from time to time. It is your responsibility to keep up to date with any changes, and to be aware of the commissions, charges, fees and costs that apply to your trades and the Services that you use.

20.5. You acknowledge that all amounts due to us shall be deducted from any of the balances of your Account.