The Financial Conduct Authority (FCA) has published a new good and poor practice document focused on pricing transparency in international payments.
The guidance forms part of the FCA’s broader efforts to embed the Consumer Duty across the sector and addresses how clearly firms communicate the true cost of cross-border transfers and money remittance services to consumers.
In this article, our experts summarise the FCA’s findings and outlines what payment, and e-money firms should consider in light of this guidance.
Examples of Good Practice
The FCA highlights several approaches that firms can adopt to meet the standards expected under the Consumer Duty, including:
- Clear disclosure of the amount the recipient will receive, allowing customers to understand the value delivered after fees and exchange rate conversions.
- Itemised breakdowns of all charges, including fixed and variable transaction fees, currency conversion charges, third-party or intermediary bank fees.
- Real-time calculation tools that display exchange rates and total costs at the point of transaction, giving users confidence in the accuracy and completeness of the pricing.
- Transparent digital journeys, where cost information is prominently displayed and easy to locate.
Such practices enable consumers to compare providers effectively, understand the impact of fees and charges, and make informed decisions aligned with their needs.
Examples of Poor Practice
The FCA also draws attention to examples of conduct that fall short of the Duty’s requirements, such as:
- Failing to display transaction fees clearly or obscuring them within broader terms and conditions.
- Omitting additional costs, such as fees charged by intermediaries or correspondent banks, which can materially reduce the amount received by the end recipient.
- Presenting pricing information inconsistently, such that consumers may need to navigate multiple pages or steps to access key details.
These practices can undermine transparency, hinder comparability between providers, and potentially result in harm to consumers — breaches in the Duty’s obligations for firms.
Expectations for Firms
In light of the findings, the FCA expects firms providing international payment services to critically assess and, where necessary, update their current disclosure and communication practices. All customer communications must be clear, fair, and not misleading, consistent with Principle 7 and the cross-cutting rules under the Consumer Duty.
Firms should regularly review their customer journeys, including website flows and app interfaces, to ensure that cost information is prominently displayed and accessible at the appropriate stages. Any refinements to how pricing is communicated should be informed by testing and customer feedback, particularly for products that carry higher risks or costs.
Finally, the FCA encourages firms to use its published guidance as a benchmark for evaluating their existing practices. This should help identify any shortcomings and support continuous improvement in delivering transparent, customer-focused outcomes.
Final Thoughts
Firms should take this opportunity to review how their cost information is displayed, assess whether their disclosures are meeting the FCA’s expectations, and ensure internal teams understand the broader regulatory context.
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