Date: 29th March 2024

Neobrokers' Inception Paper | Summary

This paper delves into the business models of neobrokers and their implications for retail investors, highlighting the transformative role these digital platforms play in the financial markets. It underscores the benefits and challenges associated with neobrokers, emphasizing the need for continuous scrutiny and regulatory vigilance to safeguard investor interests and market integrity.

Key Challenges Identified:

  • Transparency and Costs: Neobrokers often promote zero-commission trading, which can be misleading as hidden costs like bid-ask spreads exist. The real cost to investors might not always be apparent, affecting their investment decisions and outcomes.
  • Inducements and Conflicts of Interest: The practices of payment for order flow (PFOF) and inducements from ETF providers raise concerns about potential conflicts of interest and the impact on product selection and investor outcomes.
  • Securities Lending Risks: The practice of lending out investors' securities introduces counterparty and collateral shortfall risks, which could have significant implications for retail clients.
  • Regulatory Evolution: The dynamic and innovative nature of neobrokers tests current regulatory frameworks, necessitating adaptations to ensure investor protection and market integrity, as seen with the EU's Digital Finance Strategy and the PFOF ban.
  • Service Diversification: Neobrokers are expanding into banking and payment services, creating a more integrated financial service platform but also introducing new complexities and regulatory challenges.
  • Digital Advisory Services: The blending of advisory and execution-only services through digital platforms like robo-advisors and neobrokers necessitates clear delineation and transparency to prevent investor confusion and ensure informed decision-making.


  • In summary, while neobrokers provide accessible and cost-efficient entry points into the financial markets, their evolving business models and the breadth of services offered introduce several challenges that need continuous assessment and regulatory oversight to maintain a balanced and investor-centric financial ecosystem