For a long time, financial services firms have relied on signatures to prove customer agreement. Whether wet ink or digital, the assumption was that if a client signed a document, the job was done.
But the FCA’s Consumer Duty has changed that thinking. Under the new rules, it’s no longer enough to show that a customer received a document or clicked to sign it. You now need to prove that they understood it.
That shift changes the game for e-signature tools. If your signature process doesn’t go beyond formality and actually help customers understand what they’re signing, you could be falling short of FCA e-signature compliance.
This post explores what the FCA expects, where traditional signature tools miss the mark, and what firms can do to stay on the right side of the rules.
The FCA has made it clear that a signature is not enough. In the world of Consumer Duty, what matters is the outcome for the customer. Did they receive good information? Did they understand it? And did they make an informed decision?
Under the updated FCA signature rules, regulators now expect firms to:
Traditional e-signature platforms were built for speed and documentation. They make it easy to sign something quickly, track IP addresses, and store PDFs in the cloud. But they don’t do anything to support comprehension or understanding.
If a customer signs a complex legal document in 10 seconds, that might look efficient on paper. But under the FCA’s expectations, it might raise a red flag.
The concept of consumer duty consent is very different from the old definition of agreement.
In the past, getting a signed contract might have been enough to close the file. Now, the FCA expects firms to go further and ensure the customer’s consent was informed, clear and supported.
That means:
A quick scroll-and-sign interaction on a PDF simply doesn’t provide that. If a customer complains later, a signature alone won’t protect you.
Firms need to demonstrate that they took reasonable steps to help the customer make a good decision. That’s the heart of consumer duty consent.
Read more about our legal and regulatory approach.
Most e-signature providers were never designed for regulatory compliance. They were built to move documents through a process quickly, not to help customers understand them.
This creates several risk areas:
All of these issues expose firms to regulatory risk. If the FCA audits your consent process, will you be able to show that you delivered clear, understandable information and supported real understanding?
Firms that rely solely on legacy tools may struggle to answer yes to that question.
Meeting FCA e-signature compliance requirements means rethinking your signature journey from start to finish. It’s not just about putting a document in front of someone. It’s about designing an experience that leads to informed consent.
Key features of a compliant approach include:
This approach also supports firms when things go wrong. If a customer complains that they didn’t understand something, your audit trail shows not just that they signed, but that they were actively engaged in the process.
It’s a smarter and safer way to manage compliance.
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Here’s how we do it:
By focusing on understanding rather than just signatures, we help firms meet the real goals of the Duty — and reduce the risk of future complaints.
The FCA has made clear that the Consumer Duty is not just a guidance document. It is a framework they are actively using in reviews, audits and enforcement.
Firms that fail to adapt will find themselves exposed in areas like:
Relying on outdated e-signature systems is no longer a low-risk decision. The gap between what those tools provide and what the FCA expects is growing fast.
Firms that act now can get ahead of the risk. Those that wait may find themselves facing difficult conversations with the regulator — or worse, redress schemes, fines or loss of customer trust.
If you are reviewing your current processes and want to make sure they meet the new standards, we can help.
You can explore our FAQs , read about our legal and regulatory approach, or dive into use cases for financial services.
Our goal is simple: to help your customers understand what they’re agreeing to, and to help you prove it.
The days of relying on a quick click and a PDF signature are over. The FCA expects more — and so should you.
Consumer duty consent means designing processes that help real people make real decisions with confidence. It means moving beyond documentation and towards understanding.
Whether you are in lending, insurance, wealth management or any other regulated space, the signature process you use today needs to support your compliance tomorrow.
If it doesn’t, now is the time to rethink it.