The FCA has decided that explaining UTXOs is a financial promotion

Published: April 1, 2026

Today is April 1st, but this is not an April Fools’ joke. I wish it were.

If you own a hardware wallet from Ledger or Trezor and you’re based in the UK, there’s a fair chance you’ve already hit this page:

This content is temporarily unavailable to UK users - Trezor

Both companies block specific content for UK visitors. But what’s striking is that the policy now extends far beyond the usual suspects - blocked pages on peer-to-peer trading, for example, would at least be predictable. Educational articles are now blocked too. Trezor’s page about UTXOs. Ledger’s guide to best practices for hardware wallet security. Even a guide to multisig.

This is the UK’s financial promotions regime in action.

  1. What happened
  2. What’s blocked
  3. The actual cost
  4. Getting around it

Disclosure: Predictably I need to point out that this article is for general information only and does not constitute investment advice or a financial promotion.

1. What happened

The FCA’s financial promotion rules for cryptoassets came into effect in October 2023, and it covers any “invitation or inducement to engage in investment activity” involving a “qualifying cryptoasset”. Remember that the FCA is yet to make any distinction between Bitcoin - a decentralised global monetary network with a market cap approaching that of silver, running uninterrupted for over 17 years - and the latest pump & dump crypto coin.

Crucially, the offending content doesn’t need to target UK consumers to be liable. It just needs to be “capable of having an effect in the UK”: in other words, be publicly accessible on the internet.

Trezor is Czech, Ledger is French, and neither holds FCA authorisation. Breach is a criminal offence - up to two years’ imprisonment and an unlimited fine. Their response is predictable: geo-block anything that might, under a broad reading, constitute a financial promotion. It’s blunt, possibly overcautious, and not really their fault. The definition is capacious enough to catch almost anything. The criticism belongs with the regulation, not the companies.

2. What’s blocked

Trezor

I scanned 421 pages across Trezor’s site. Around 40 are blocked for UK visitors. They return HTTP 200 - so not even a proper error code - but serve a blank page instead of the article, with the heading: “This content is temporarily unavailable to UK users.”

“Temporarily” - let's hope that's true...
“Temporarily” - let's hope that's true...

Some blocked pages are predictable. Every guide to buying, selling, swapping, and staking crypto through Trezor Suite is gone. These probably do constitute financial promotions under the letter of the law, so it’s hardly surprising that they’re blocked.

But the block extends far beyond this.

Blocked pageWhat it is
What is a hardware wallet?An explanation of the product you just bought
Public & private keysCryptography fundamentals
What is a UTXO?How Bitcoin transactions work
What is a change address?Transaction mechanics
What is multisig?Multi-signature security, widely used in inheritance planning
Using Bitcoin testnet with TrezorDeveloper testing with fake coins

Meanwhile, the pages explaining what CoinJoin is and how to use Tor with Trezor Suite are fine. So is the entire Trezor blog, including a post titled Unlock financial freedom in just 4 steps: master crypto security and be your own bank. Promoting financial freedom is apparently fine. Explaining what a change address is - not so much.

The sheer incongruity of the blocked pages suggests a hasty compliance exercise rather than deliberate targeting. Slapdash, in other words - the predictable result when loosely-written regulation meets a legal team working to a deadline.

Ledger

Ledger is “actively working to get all Ledger webpages available again.” Please keep at it, Ledger.
Ledger is “actively working to get all Ledger webpages available again.” Please keep at it, Ledger.

Ledger’s approach is simpler: block almost everything and work backwards. Their message: “Due to new rules in the UK, certain Ledger.com webpages are restricted. We are actively working to get all Ledger webpages available again.”

Their Academy landing page is accessible. The articles are not. Neither is the blog, nor /buy or /swap.

Blocked pageWhat it is
What is a crypto wallet?An explanation of the product you just bought
Bitcoin UTXOs explainedHow Bitcoin transactions work
Best practices for using a hardware walletSecurity and safety advice
Which Ledger device is best for me?Product selection guide
What is multisig?A wallet security method
What is staking?An explanation of how staking works

An exception: multisig.ledger.com — the enterprise multisig product — is fully accessible. So you can purchase the product, you just can’t read about what multisig means.

For what it’s worth, Coldcard, BitBox, and many others don’t appear to be applying the same restrictions. Their educational content remains accessible to UK visitors. Whether that reflects a different legal reading, a different risk appetite, or simply a smaller compliance team’s to-do list, I don’t know.

3. The actual cost

The financial promotions regime wasn’t designed for this. It was meant to stop predatory crypto advertising: pump-and-dump scams, misleading yield claims, celebrity endorsements for projects whose entire value proposition is vibes. To my mind, that’s a legitimate goal.

Instead, it’s caught UK users who already own a hardware wallet and now can’t access the documentation to use it properly. Users are now less safe as a direct result of this legislation. Proper coin control requires an understanding of UTXOs and change addresses. Creating a resilient multisig setup for your family requires, at minimum, understanding what multisig is. None of this is promotional.

The FCA’s definition doesn’t distinguish between a tutorial on transaction mechanics and a flyer for a memecoin.

Lady Justice, courtesy of ChatGPT.
Lady Justice, courtesy of ChatGPT.

4. Getting around it

I have three options for you.

Wrapping up

This is par for the course. The UK government has form on this. The financial promotions regime is a reasonable idea, badly executed. The definition is broad enough to catch “what is a UTXO”, while the penalties are severe enough that companies have chosen geo-blocking as a catch-all fix. UK residents are left less informed about how to use technology they own.

The information is still out there - in textbooks, GitHub repos, Bitcoin meetups, and a thousand other websites the FCA hasn’t yet targeted as cryptoasset promotions. But while the UK government figures itself out, a VPN is now required.

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