Customer outcomes, complaints, vulnerable customers, financial promotions, governance, board reporting and independent reviews for payment and e-money firms, delivered to the standard the FCA supervises against.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money, cryptoasset and consumer credit firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
Payment and e-money firms show the FCA how their products, pricing, communications and support deliver good outcomes for customers. For an EMI or payment institution the Duty runs through onboarding, fees, payment journeys, communications, complaints, vulnerable customers, financial promotions, customer support and operational resilience.
We help firms implement, evidence and strengthen their arrangements: governance, outcome monitoring, fair value, customer understanding and support, with the records a supervisor asks for. The firm has supported payment, e-money and fintech businesses on authorisation and compliance since 2013, and every engagement is led by senior regulatory specialists.
Governance, customer outcome monitoring, policies, management information, board reporting and remediation plans that evidence the firm’s arrangements.
Policies, MI, complaints, customer communications and outcome testing reviewed, with findings and remediation actions.
Training for boards, senior managers, compliance teams and customer-facing staff, focused on practical obligations and evidence.
Existing policies tested against the Duty’s principles, and new ones written to promote fair treatment and better outcomes.
Complaint root causes, policies and processes reviewed against the Duty, with recommendations and the key complaint policies written.
A plan tailored to the firm, with steps, actions, objectives and resources.
Policies and procedures tested so that customers in vulnerable circumstances receive good outcomes and fair treatment across the journey.
An objective assessment of the firm’s adherence to the Duty, with recommendations for improvement.
Promotions reviewed against the regulatory requirements and the consumer understanding outcome.
| Deliverable | What it contains | Who relies on it |
|---|---|---|
| Gap assessment | The firm’s arrangements tested against the four outcomes and cross-cutting rules, with prioritised findings | Board, compliance |
| Outcome monitoring framework | Measures, data sources, thresholds and the MI pack for each outcome | Board, FCA |
| Policy set | Consumer Duty, fair value, vulnerable customers, complaints and financial promotions policies | Staff, FCA |
| Annual board report | The assessment of outcomes delivered and the actions agreed | Board, FCA |
| Independent review report | Findings, severity, owners and recommendations | Board, audit committee |
Yes. It has applied to open products and services since 31 July 2023 and to closed products since 31 July 2024. For payment services and e-money, retail customers include consumers, micro-enterprises and small charities with annual income under £1 million.
Products and services, price and value, consumer understanding, and consumer support. The firm evidences each one, alongside the cross-cutting rules to act in good faith, avoid foreseeable harm and support customers to pursue their financial objectives.
Governance records, outcome monitoring and management information, complaints data and root-cause analysis, vulnerable customer arrangements, communications testing, fair value assessments, board reporting and documented remediation where outcomes need to improve.
Yes. The board, or equivalent governing body, reviews and approves a report at least once a year assessing whether the firm is delivering good outcomes, with the actions it will take.
Yes. The review assesses the firm’s arrangements objectively against the rules and guidance and gives prioritised recommendations, reported to the board.
Yes. We review promotions and customer communications against the financial promotion rules and the consumer understanding outcome before they are published.
A reply within three business hours and a written proposal on scope, cost and timing the same day.