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K-CMH calculator

Client money held is the only K-factor with two coefficients for the same asset. Money in segregated accounts attracts 0.4%; money that is not segregated attracts 0.5%. Whether an account qualifies is a legal test, not an operational label — and it is set by a separate delegated regulation.

IFR Art. 18 measurement · Art. 15(2) 0.4% segregated · 0.5% non-segregated · nothing stored

Calculate K-CMH

Runs in your browser · nothing uploaded

Enter the rolling average of total daily client money held, split between segregated and non-segregated. Under Article 18 that average runs at the end of each business day over the previous nine months, excluding the three most recent, leaving six months of daily values.

Client money held

Article 18 · end of each business day, six months of values
Held in segregated accounts Art. 15(2) coefficient · 0.4% “Segregated” is defined by delegated regulation for this purpose — the conditions that must be met to protect client money if the firm fails. An account labelled client money internally does not automatically qualify.
Held in non-segregated accounts Art. 15(2) coefficient · 0.5% 25% more capital per unit than segregated money. If you are unsure which side a balance falls, put it here and check the conditions.
What this means: an indicative figure from the averages you supplied. It does not build the Article 18 series, and it cannot determine whether an account meets the segregation conditions — which is the substantive question and the one that moves the number. This is not advice.

The segregation split is a capital decision, not a bookkeeping one. Pillar 1 Capital maintains the daily series for every K-factor and shows which limb binds — with free capital monitoring to start.

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The split

Two coefficients, one asset

No other K-factor prices the same balance two ways. It is worth understanding why, and what the difference costs.

0.4%

Segregated

The lower calibration applies where client money is held in an account meeting the segregation conditions set by delegated regulation, so it is protected if the firm fails.

0.5%

Non-segregated

Twenty-five per cent more capital for the same balance. The premium is the price of the client’s money being exposed to the firm’s own insolvency.

Daily

Nine months less three

Measured at the end of each business day over nine months, excluding the three most recent, leaving six months of daily values. Calculated on the first business day of each month.

Rules reviewed 21 August 2026 · IFR (EU) 2019/2033 Art. 15(2), 16 and 18 · segregated accounts specified by Commission Delegated Regulation under Art. 15(5)(b)

Scope

What this calculator does

It doesApply both coefficients

  • Applies 0.4% to segregated and 0.5% to non-segregated balances and sums them.
  • Converts period totals into daily averages where needed.
  • Shows what the split is costing you against a fully segregated position.
  • States the Article 18 window and calculation point alongside the figure.

It does notTest segregation

  • Determine whether an account meets the segregation conditions in the delegated regulation.
  • Construct the nine-month daily series or apply the three-month exclusion.
  • Reconcile client money records or test compliance with client asset rules.
  • Calculate any other K-factor.

K-CMH is one of four RtC factors

Risk-to-Client is K-AUM plus K-CMH plus K-ASA plus K-COH. The combined calculator adds them in one place.

RtC K-factor requirement →

Nothing you type here leaves your browser

The calculation runs entirely in your own browser. No figure you enter is sent to REGREP, written to a log, saved, or passed to any analytics tool.

Questions

About K-CMH

What period does CMH cover?

Article 18 takes the rolling average of the value of total daily client money held, measured at the end of each business day over the previous nine months, excluding the three most recent months. CMH is the arithmetic mean of the daily values from the remaining six months, and K-CMH is calculated on the first business day of each month.

Why are there two coefficients?

Article 15(2) sets 0.4% for client money held in segregated accounts and 0.5% for non-segregated accounts. The lower calibration recognises that segregation protects client money if the firm fails, so the risk being capitalised is smaller.

What counts as a segregated account?

Not simply an account you label as client money. The EBA was mandated under Article 15(5)(b) to specify the notion of segregated accounts, and a Commission Delegated Regulation sets the conditions that must be fulfilled to ensure client money is protected in the event of the firm’s failure. Whether a particular arrangement qualifies is a legal question about those conditions.

How much does the split actually cost?

The non-segregated coefficient is 25% higher, so every million of client money moved from segregated to non-segregated adds five hundred rather than four hundred to the requirement. On large balances the difference is material, and it is one of the few K-factor outcomes a firm can influence by changing how it holds money rather than what business it does.

Do you store the figures I enter?

No. Everything is calculated in your browser and discarded when you close or reload the page.

One of the few K-factors you can actually manage.

Create a free account and track client money held alongside every other factor, continuously.

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