Application of Consumer Duty to Payment & E-money firms

The Duty will require firms to act to deliver good outcomes for customers (including those in vulnerable circumstances).

The Duty applies to products and services provided to prospective and actual “retail customers”. For payment and e-money firms, this means business conducted with retail consumers, including to micro-enterprises and small charities with turnover of less than £1 million.

Payment and e-money firms must ensure that product and services are designed to meet the needs, characteristics and objectives of a specified target market.

Payment and e-money firms must ensure that price and value of products and services provide fair value with a reasonable relationship between the price consumers pay and the benefit they receive.

Payment and e-money firm must ensure that it communicates in a way that supports consumer understanding and equips consumers to make effective, timely and properly informed decisions.

Payment and e-money firm must ensure that it provide support that meets consumers’ needs throughout the life of the product or service.

A key part of the Duty is that firms are able to define, monitor, evidence and stand behind the outcomes their customers are experiencing. This monitoring must enable firms to identify where customers, or groups of customers, are experiencing poor outcomes, and where this is the case firms must take appropriate action to rectify the situation.  

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