We have delivered consumer duty projects for the following clients
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Why payment and e-money firms work with us
Specialist focus
We advise payment and e-money firms on UK and European authorisation, compliance and regulator engagement.
Experience since 2013
We have supported applicant and regulated firms across EMI, Payment Institution and fintech authorisation projects for over a decade.
Consumer Duty services for payment and e-money firms
Consumer Duty implementation and evidence
We help firms evidence Consumer Duty arrangements through clear governance, customer outcome monitoring, policies, MI, board reporting and remediation plans.
Consumer Duty reviews and policy support
We review Consumer Duty policies, MI, complaints, customer communications and outcome testing, then provide clear findings and remediation actions.
Board and staff training
We deliver Consumer Duty training for boards, senior management, compliance teams and customer-facing staff, focused on practical obligations and evidence.
Policy and Procedure Review
We can review your firm's existing policies and procedures to ensure they align with the Consumer Duty principles. We can help develop new policies and procedures to promote fair treatment and better outcomes for consumers.
Complaint handling
We can review your complaint handling root causes, policies and processes against the consumer duty requirements and provide recommendations, as well as create your key policies.
Implementation Planning
We can assist in developing a tailored implementation plan that outlines the necessary steps and actions to ensure compliance with the Consumer Duty, including setting objectives, and allocating resources effectively.
Vulnerable customers
We can help ensure that your policies and procedures are adequate and that vulnerable customers are receiving good outcomes and are being treated fairly throughout the customer journey.
Independent Consumer Duty reviews
We can offer independent reviews of your firm's adherence to the Consumer Duty requirements, providing an objective assessment of your practices and recommendations for improvement.
Financial promotions
We can help ensure that your financial promotions meet the consumer duty regulatory requirements and help deliver good customer outcomes.
Consumer Duty for payment and e-money firms
"The Consumer Duty will lead to a major shift in financial services and will promote competition and growth based on high standards."
Payment and e-money firms need to evidence how products, pricing, communications and support arrangements deliver good customer outcomes. For EMIs and Payment Institutions, Consumer Duty often links directly to onboarding, fees, payment journeys, customer communications, complaints, vulnerable customers, financial promotions, customer support and operational resilience. The key evidence usually includes governance records, outcome monitoring, complaints MI, root-cause analysis, vulnerable customer arrangements, board reporting, customer communications reviews and documented remediation where weaknesses are identified.
Key Consumer Duty issues for payment and e-money firms
Cultural Transformation
One of the primary challenges for firms is the need for a cultural transformation. Shifting towards a customer-centric culture requires a fundamental change in mindset, practices, and processes within the organisation.
Enhanced Compliance Requirements
The Consumer Duty introduces new compliance requirements that firms must meet. This includes a deeper understanding of the regulatory framework, ensuring robust systems for monitoring customer outcomes, and demonstrating evidence of compliance.
Tailoring Products and Services
Firms must tailor their products and services to meet the diverse needs of retail customers. This requires a deep understanding of customer segments, conducting thorough market research, and implementing product development strategies that prioritize customer outcomes. Adapting existing offerings or creating new ones may pose challenges in terms of resources, expertise, and time.
Communication and Transparency
The Consumer Duty places a significant emphasis on clear and transparent communication with customers. Firms need to ensure that their communication strategies, including marketing materials, product disclosures, and customer interactions, provide accurate and easily understandable information. Maintaining transparency while complying with regulatory requirements can be a delicate balance that firms need to navigate.
Support for Vulnerable Customers:
Meeting the needs of vulnerable customers presents a unique challenge for firms. Firms must develop strategies and processes to identify and provide appropriate support to vulnerable customers, ensuring their financial well-being and protecting them from potential harm. This may involve training staff, implementing additional safeguards, and offering tailored services to cater to the specific needs of vulnerable customers.
Our People
Our Consumer Duty work is led by senior regulatory specialists with experience across payment services, e-money, complaints, vulnerable customers, financial promotions, governance and FCA supervisory expectations.
Our insights on the Consumer Duty
