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FCA Consumer Duty Compliance for Financial Services: Proving Informed Consent Across Every Product

i agree helps financial services firms meet FCA Consumer Duty requirements, reduce mis-selling risk, and prove that clients genuinely understood what they agreed to — across every product and touchpoint.

i agree helps financial firms meet Consumer Duty standards, reduce risk, and build trust at every client touchpoint.

Mortgage Agreements: Proving Informed Consent and Meeting FCA Consumer Duty for Lenders

Mortgage agreements

Use it for:

Helping clients understand and consent to key terms like interest rates, fees, and repayment structure.

Why it matters:

Mortgages are complex and often misunderstood. Under FCA Consumer Duty, lenders must ensure clients genuinely understand the terms, not just collect signatures. Most borrowers do not read or fully comprehend their mortgage contracts, which can lead to complaints, financial hardship, or mis-selling claims.

Value added:


  • Demonstrates compliance with Consumer Duty
  • Reduces disputes over repayment terms or penalties
  • Builds trust through transparency
  • Creates a clear audit trail of informed consent
  • Improves client understanding and confidence

 

Mortgage lenders operating under FCA Consumer Duty are required to demonstrate that customers understood the key features of their product — including interest rates, total cost of borrowing, early repayment charges, and what happens if payments are missed — before committing. A signed application form does not satisfy this standard. i agree's timestamped consent audit trail provides exactly the evidence regulators expect: what was shown, when it was shown, and that the client confirmed their understanding before proceeding. 

Personal Loans and Credit Cards: Reducing Mis-Selling Risk and Supporting Responsible Lending

Use it for:

Clarifying terms like APR, total cost of borrowing, fees, and repayment obligations.

Why it matters:

Many clients sign loan agreements without understanding them. Poor understanding leads to debt stress, defaults, and complaints. Consumer Duty requires firms to enable informed borrowing decisions.

Value added:


  • Supports responsible lending
  • Reduces late payment disputes
  • Protects against mis-selling claims
  • Enhances borrower engagement
  • Enables proactive identification of vulnerable customers
Personal loans

Consumer Duty places a direct obligation on lenders to ensure borrowers understand the true cost of credit before signing. For personal loans and credit cards, this means clearly communicating APR, total repayable amounts, missed payment consequences, and any fees — in a format the customer can genuinely engage with. i agree turns these disclosures from a compliance checkbox into an interactive consent journey, capturing confirmation that the borrower saw and understood each material term before the agreement was executed. 

Buy Now Pay Later (BNPL): FCA-Compliant Informed Consent at the Point of Sale

BNPL

Use it for:

Presenting repayment schedules, late fees, and credit impact disclosures during checkout.

Why it matters:

BNPL products are designed to feel frictionless — and that frictionlessness is precisely the problem from a regulatory perspective. Most users click through a BNPL checkout in seconds without reading the repayment terms, late fee structure, or credit reporting implications. Research consistently shows that many BNPL users are surprised to discover that missed payments can affect their credit score or trigger penalty charges they did not expect.

The FCA is actively moving to regulate the BNPL sector. Under the incoming framework, BNPL providers will be required to conduct affordability assessments and ensure customers understand the credit terms before agreeing — bringing BNPL into line with the Consumer Credit Act and FCA Consumer Duty standards that apply to other forms of lending. Providers who have already embedded a clear, auditable consent process will be significantly better positioned when regulation takes effect.

Value added:


  • Ensures real-time, informed consent
  • Reduces chargebacks and missed payment disputes
  • Improves conversion through transparent UX
  • Shows regulators commitment to fair practice
  • Encourages sustainable use of credit

The FCA's incoming regulation of the BNPL sector will require providers to demonstrate that consumers understood the credit terms before agreeing — including repayment schedules, late payment fees, and the impact on credit files. i agree helps BNPL providers get ahead of these requirements by capturing real-time informed consent at the checkout stage, before regulation makes it mandatory. Embedding a clear, auditable consent step into the purchase journey also reduces chargebacks and missed payment disputes by ensuring customers genuinely understood the commitment they were making. 

Insurance Policy Onboarding: Reducing Rejected Claims and Ombudsman Complaints

Use it for:

Breaking down what’s covered, what’s excluded, and when the policy pays out.

Why it matters:

Most clients don’t read or understand their insurance policies. This leads to confusion or anger when claims are denied. Firms must present exclusions and conditions clearly.

Value added:


  • Reduces rejected claims and complaints
  • Protects against ombudsman rulings
  • Demonstrates fair treatment
  • Boosts retention and cross-sell potential
  • Provides a record of what was disclosed
Insurance policy

Insurance complaints frequently arise when customers discover that a claim is excluded under a policy condition they were never clearly told about. Under Consumer Duty, insurers and brokers must ensure policy exclusions, conditions and limitations are communicated in a way customers can actually understand — not buried in a 40-page policy document. i agree presents these key terms at the point of onboarding, captures confirmation that the customer saw them, and creates a logged record that can be produced if an ombudsman complaint is raised. 

Savings Accounts and Fixed-Term Deposits: Transparent Onboarding That Meets FCA Consumer Duty

Savings accounts

Use it for:

Presenting key terms like interest rates, withdrawal conditions, account fees, and FSCS protection at the point of account opening.

Why it matters:

Savings products often come with limitations or conditions that are poorly understood—such as early withdrawal penalties or interest calculation methods. FCA guidance requires that customers are aware of important terms before committing their money.

Value added:


  • Ensures customers understand access restrictions and return expectations
  • Reduces complaints about penalties or lower-than-expected interest
  • Demonstrates transparent onboarding practices
  • Builds trust in savings and deposit products
  • Aligns with Consumer Duty expectations for clarity and fairness

 

Savings customers frequently complain about penalties or returns that were lower than expected — often because the access restrictions or interest conditions were not clearly communicated at the point of opening. Consumer Duty requires firms to ensure customers understand the key features of savings products, i agree makes these disclosures an active part of the account opening journey rather than a passive terms and conditions document that most customers never read. 

Equity Release: Informed Consent for Vulnerable Clients and FCA Compliance

Use it for:

Helping clients understand the long-term implications of releasing equity from their home, including interest accrual, impact on inheritance, and repayment conditions.

Why it matters:

Equity release is a complex financial decision often made by older or vulnerable clients. Many do not fully grasp the costs, risks, or alternatives. FCA rules require clear, accessible explanations and evidence of informed consent.

Equity release

The FCA's finalised guidance on the fair treatment of vulnerable customers (FG21/1) places specific obligations on firms when dealing with clients who may have reduced capacity to make complex financial decisions. Equity release clients — who are often older, may be dealing with bereavement or health issues, and are making decisions that directly affect their family's inheritance — are a textbook example of a customer group that requires additional care. Firms must be able to demonstrate not just that information was provided, but that it was provided in a format and at a pace that the individual client could genuinely engage with.

i agree directly supports compliance with FG21/1 by offering:

  • Multi-format content delivery — clients can read, watch or listen to the same key information depending on what works best for them
  • Slower-paced consent journeys — no pressure to proceed quickly; clients can pause, replay and revisit at any point
  • Plain English summaries — complex financial concepts like compound interest and inheritance implications are explained in accessible language before the full legal terms are presented
  • A full interaction log — recording which formats the client engaged with, how long they spent on each section, and what they confirmed, giving firms evidence that reasonable steps were taken for that specific individual

Value added:


  • Ensures clients understand compounding interest and long-term costs
  • Reduces future disputes with family or beneficiaries
  • Demonstrates compliance with Consumer Duty and vulnerability guidelines
  • Builds trust and reassures clients in a sensitive moment
  • Captures detailed, structured records of consent and explanation

Equity release is one of the highest-risk product categories in UK financial services, typically involving older clients making irreversible decisions with significant long-term consequences. The FCA's guidance on vulnerable customers (FG21/1) places additional obligations on firms when dealing with clients who may be less able to engage with complex financial information. i agree supports compliance with this guidance through multi-format content delivery — clients can read, watch or listen to key information — and slower-paced consent journeys designed specifically for clients who need more time to process what they are agreeing to. 

Pension Transfer Advice: Defensible Consent Records to Protect Against FCA Sanctions and Mis-Selling Claims

Pension transfer advice

Use it for:

Disclosing risks and consequences of moving defined benefit pensions or withdrawing large sums.

Why it matters:

Pension transfer mis-selling has resulted in some of the largest redress programmes in UK financial services history. The FCA has repeatedly found that advisers failed to adequately communicate the risks of transferring defined benefit pensions — particularly the loss of a guaranteed income stream and the irreversible nature of the transfer. The British Steel Pension Scheme redress programme and similar cases have demonstrated the scale of harm that results when clients make pension decisions without genuinely understanding what they are giving up.

FCA rules require advisers to provide a personalised recommendation and ensure the client understood the key risks before proceeding. A client signing a suitability report is not sufficient evidence of that understanding — the FCA expects firms to be able to show what disclosures were made, in what format, and that the client engaged with and acknowledged them.

i agree gives pension transfer advisers:

  • A structured risk disclosure journey — presenting the key risks of transferring (loss of guaranteed income, inflation protection, spouse benefits) as individual, confirmable steps rather than a block of text in a suitability report

  • Voice or video confirmation — capturing the client verbally acknowledging each material risk in their own words, creating the strongest possible evidence of informed consent

  • A timestamped audit trail — logging every disclosure, every confirmation, and every question asked, in a format that can be produced to the FCA, the Financial Ombudsman, or a court if required

  • Exportable records — consent evidence can be downloaded and added to the client file, integrated with your back-office system via API, or stored separately for regulatory audit purposes

Value added:


  • Provides evidence of informed decisions
  • Shields advisers from liability and FCA sanctions
  • Reduces costly complaints and compensation
  • Improves adviser-client conversations
  • Shows commitment to long-term client outcomes

Pension transfer mis-selling has resulted in some of the largest redress programmes in UK financial services history. The FCA has made clear that advisers must evidence that clients understood the risks of transferring defined benefit pensions — including the loss of guaranteed income and the irreversible nature of the decision — before proceeding. i agree creates a step-by-step consent record that logs exactly what risk disclosures were shown, what the client confirmed, and when — giving advisers a defensible audit trail that protects against future liability claims and FCA enforcement action.

Open Banking and Data-Sharing Consent: GDPR-Compliant Consent Capture for Fintech and Banks

Use it for:

Explaining who will access financial data, for what reason, and what control the client retains.

Why it matters:

Clients hesitate or rush through consents for data-sharing. Misunderstandings damage trust and invite GDPR breaches. Clear explanations build confidence.

Value added:


  • Drives engagement with new digital services
  • Demonstrates compliant data practices
  • Boosts trust in fintech and bank brands
  • Reduces support queries and consent disputes
  • Encourages wider adoption of Open Banking tools
Open banking

GDPR and the UK Data Protection Act 2018 require that consent for data sharing is freely given, specific, informed and unambiguous. For open banking and fintech products, this means clearly explaining who will access the customer's financial data, for what purpose, and for how long — in plain English rather than buried in a privacy policy. i agree captures each of these consent elements separately, creating a granular consent record that satisfies both GDPR requirements and FCA expectations for transparent data practices. 

 

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CRM and API Integration for Financial Services Firms

Have an internal system or CRM? i agree works with your tools via API and webhooks. Automatically trigger consent flows, store audit records, and get notified when clients respond — all from your existing setup.

FCA Consumer Duty and Informed Consent for Financial Services: Frequently Asked Questions

How does i agree help financial services firms meet FCA Consumer Duty requirements? 

The FCA Consumer Duty requires firms to prove that customers genuinely understood the products and services they were sold — not just that they signed a document. i agree delivers this by presenting key product terms in plain English, using voice and video explainers to support comprehension, and capturing a timestamped consent record at every stage. This gives firms verifiable evidence of the Customer Understanding Outcome required under FG22/5, Section 8.

Does i agree work for FCA-regulated products like mortgages, pensions and insurance?

Yes. i agree is designed specifically for regulated financial products where informed consent and clear communication are a regulatory requirement. It works across mortgages, personal loans, BNPL, insurance, equity release, pension transfers, savings products and open banking consent — capturing the same standard of defensible consent evidence for each.

How does i agree help with vulnerable customer requirements?

The FCA's guidance on vulnerable customers (FG21/1) requires firms to adapt their communications for clients who may be less able to engage with standard formats. i agree supports this through multiple format options — clients can read, listen or watch the same information — as well as slower-paced journeys and simplified content modes. Every vulnerable customer receives the same quality of informed consent process, with the same audit trail, as any other client.

Can i agree reduce Financial Ombudsman Service complaints for financial firms? 

Yes. A significant proportion of FOS complaints in financial services stem from customers claiming they didn't understand what they were agreeing to. By ensuring clients engage with key terms before proceeding — and capturing a record that proves it — i agree removes the "I didn't know that" basis for many common complaints. If a complaint is raised, your consent audit trail provides clear evidence of what was explained and confirmed. 

Does i agree help with mis-selling risk in financial services?

Yes. Mis-selling claims often arise when clients say they were not properly informed about fees, risks, or conditions. i agree reduces this risk by making key disclosures an active part of the client journey rather than buried in small print — and by capturing confirmation that the client saw and understood them. This is particularly valuable for high-risk products like pension transfers, equity release and BNPL where mis-selling consequences are most severe.

Is i agree compliant with GDPR for data-sharing and open banking consent?

Yes. For data-sharing and open banking use cases, i agree captures consent that is freely given, specific, informed and unambiguous — meeting the GDPR requirements for valid consent under the UK Data Protection Act 2018. Every consent record is timestamped, tied to the specific purpose explained to the client, and exportable for compliance or audit purposes.

If you have more questions, take a look at our full FAQs page where we cover a wider range of topics in more detail. It’s a quick way to find answers and explore other subjects that might be useful to you.