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K-COH calculator

Client orders handled is one of the more approachable K-factors: two coefficients, one rolling average, no trading book. The catch is the measurement window — six months, with the three most recent excluded — so the figure you owe next month was fixed by business you did last quarter.

IFR Art. 20 measurement · Art. 15(2) coefficients · cash 0.1% · derivatives 0.01% · nothing stored

Calculate K-COH

Runs in your browser · nothing uploaded

Enter the rolling average of total daily client orders handled for each category. Under Article 20 that average runs over each business day of the previous six months, excluding the three most recent months, and is calculated on the first business day of the month.

Client orders handled

Article 20 · sum of the absolute value of buys and sells
Cash trades Art. 15(2) coefficient · 0.1% Orders in cash instruments, executed in the name of the client or received and transmitted. Include amounts arising from investment services carried out by your tied agents.
Derivatives Art. 15(2) coefficient · 0.01% Measured by notional value. The coefficient is ten times lower than for cash, so the split materially changes the result.
What this means: an indicative figure from the averages you supplied. It does not calculate the Article 20 rolling average itself, and that calculation — which business days count, how the three-month exclusion is applied, and how tied agent activity is captured — is where the work and the errors sit. K-COH is one component of the K-factor requirement, which is itself only one of three limbs of your own funds requirement. This is not advice.

K-COH moves every month, on a window that closed three months ago. Pillar 1 Capital keeps the rolling averages current across every K-factor and shows which limb is binding — with free capital monitoring to start.

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The window

Why the number lags your business

Article 20 deliberately measures the past rather than the present, and the shape of that window surprises people.

Six months

The observation period

COH is the rolling average of total daily client orders handled, measured over each business day of the previous six months.

Minus three

The exclusion

The three most recent months drop out. So the average is built from months four to six before the calculation date — only three months of daily values, not the half-year just gone.

Monthly

The calculation point

K-COH is calculated on the first business day of each month, so the requirement steps rather than drifts, and a busy quarter arrives in your capital requirement two quarters later.

EBA Q&A 2022_6384 confirms the reading below · Rules reviewed 21 August 2026 · IFR (EU) 2019/2033 Art. 15(2), 16 and 20

Scope

What this calculator does

It applies two coefficients. The measurement underneath them is left with you, deliberately.

It doesApply the Article 15(2) coefficients

  • Applies 0.1% to cash trades and 0.01% to derivatives, and sums them.
  • Converts a period total into a daily average where you do not already have one.
  • Shows each component separately, so the effect of the cash and derivative split is visible.
  • Flags where a small change in the split would materially move the result.
  • States the Article 20 window and calculation point alongside the figure.

It does notMeasure COH

  • Calculate the Article 20 rolling average, or apply the three-month exclusion.
  • Determine which orders are executed in the name of the client versus received and transmitted.
  • Include tied agent activity, which must be captured in the underlying figures.
  • Calculate any other K-factor, or the K-factor requirement as a whole.
  • Produce anything you can file. It is a calculator, not a return.

K-COH is one input, not the answer

Your own funds requirement is the highest of the permanent minimum requirement, the fixed overheads requirement and the sum of all your K-factors.

Own funds 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 to a database, or passed to any analytics tool.

Questions

About K-COH

What period does COH cover?

Under Article 20, COH is the rolling average of the value of the total daily client orders handled, measured throughout each business day over the previous six months, excluding the three most recent months. K-COH is then calculated on the first business day of each month.

Which coefficients apply?

Article 15(2) sets 0.1% for client orders handled in cash trades and 0.01% for derivatives. The ten-fold difference means the split between the two categories moves the result far more than a proportionate change in total volume.

How are orders valued?

By the sum of the absolute value of buys and sells, so purchases and sales do not net against each other. Derivatives are measured by notional value.

Do orders handled by tied agents count?

Yes. Amounts relating to investment services and activities carried out by your tied agents must be included, so those volumes cannot be used to reduce the K-factor.

Does a Class 3 firm calculate K-COH?

No. A small and non-interconnected firm has no K-factor requirement at all under Article 11(2), and takes the higher of the permanent minimum requirement and the fixed overheads requirement instead.

Do you store the figures I enter?

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

Eight K-factors, eight rolling windows.

Create a free account and track them together, so the requirement is something you see coming.

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