Customer communication is under more scrutiny than ever.
The FCA’s Consumer Duty has raised the bar for clarity, fairness, and proof that customers receive and understand key information. At the same time, falling letter volumes and postal reform are reducing delivery days, creating new pressure on timing and reliability.

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For financial institutions, this means old communication processes are no longer enough. To stay compliant, firms must create communication workflows that are verifiable, consistent, and accessible to every customer.
This article explains exactly how to do that.

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What the FCA Expects from Customer Communications

Clear, Fair, and Not Misleading

Under the FCA’s Consumer Duty, all communications must be “clear, fair, and not misleading” and must support good customer outcomes. Firms must show they have taken steps to ensure messages are easy to understand, especially for customers who may struggle with technical or complex information (FCA, 2022, p.14).

This includes:

• Simple language
• Clear structure and hierarchy
• Consistent tone across all templates
• Avoiding long paragraphs, jargon, or ambiguous instructions

Poorly written or inconsistent communications are a recognised cause of customer harm (FCA, 2024).

Internal link: This aligns directly with our pillar article on finance communication modernisation.

Accessible to All Customers

The FCA expects firms to support customers who are digitally excluded, older, or vulnerable.
According to Ofcom, 12 percent of UK adults remain offline or rarely go online (Ofcom, 2024, p.6).

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This means digital-only communication can risk non-compliance. Certain notices must also legally be sent in writing, including arrears communications and some contractual updates (FCA Handbook, MCOB/CONC, 2024).

Implication:
A compliant process must allow for:

• Email
• SMS
• Print
• And routing rules to determine when each is used

Print cannot be removed from the communication mix.

Evidence of Delivery

The FCA requires firms to demonstrate that customers:

1. Received the communication
2. Had a fair chance to read it
3. Were not disadvantaged by the delivery method

This expectation appears across Consumer Duty, arrears guidance, and SYSC controls (FCA, SYSC 3.2).

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Email alone is insufficient because:

• Messages can bounce
• Customers can ignore or miss them
• Spam filters can divert essential content

Postal reform is reducing delivery days from six to three, which adds further risk to time-sensitive statements and notices (Ofcom, 2025). To remain compliant, firms need communication workflows that are provable, traceable, and supported by secure audit logs.

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Why Many Institutions Still Struggle With FCA Compliance

Fragmented Legacy Systems

Most financial organisations still rely on a mix of legacy tools and siloed processes.
Different teams create their own templates, run their own mailings, and store their own data.

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The FCA has repeatedly highlighted template inconsistency as a cause of poor outcomes (FCA, 2024).

Limited Audit Trails

Manual print and standalone email systems often lack reliable logs showing:

• When a message was sent
• Which channel was used
• Whether it was delivered
• Whether it was engaged
• What happened if it failed

Missing this evidence exposes firms to regulatory scrutiny.

Digital-Only Approaches Are Risky

Digital communication is fast, but it is not compliant for every customer.

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The Equality Act requires firms to offer accessible formats, including print, where needed.
Customers who are digitally excluded, vulnerable, or simply prefer hard copy must be supported.

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Building FCA-Proof Communication Workflows

Centralised Template Control

To meet FCA clarity and consistency requirements, firms need a central place to:

• Manage templates
• Apply version control
• Lock approved content
• Track changes
• Ensure tone and structure remain compliant

This removes risks caused by outdated or inconsistent documents.

Multi-Channel-Intelligent-Comms by Design

The communication channel should not be left to chance.

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Financial institutions should set routing rules based on:

• Message type (e.g., arrears → print)
• Customer preference
• Urgency
• Accessibility needs
• Compliance obligations

A robust workflow might look like:

• “IF customer chooses digital → send EMAIL”
• “IF notice is legally required → send PRINT”
• “IF urgent → send SMS + EMAIL”

This ensures fairness and consistency, while reducing operational complexity.

Fallback-to-Print for Guaranteed Delivery

This is essential for FCA compliance.

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If an email fails, bounces, or remains unopened for a defined period, a printed version is automatically triggered.
This ensures important information always reaches the customer, something the FCA expects firms to demonstrate if challenged.

Full Audit Trails for Every Message

To meet SYSC requirements, institutions need timestamped logs showing:

• When a message was created
• When and how it was delivered
• Customer engagement activity
• Whether fallback processes triggered
• When printed items were handed to Royal Mail

This evidence is crucial during audits, disputes, or remediation work.

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Data Protection and Security Requirements

Encryption and Data Minimisation

Under UK GDPR, personal data must be:

• Encrypted at rest
• Encrypted in transit
• Access controlled
• Minimised to what is necessary

Automated workflows reduce unnecessary handling of sensitive data.

Controlled Data Retention

Institutions must adhere to strict retention rules, ensuring documents are not kept longer than legally required. Multi-channel-intelligent-comms can automate retention schedules and apply consistent deletion policies.

ISO and Accreditation Standards

Micom operates to:

• ISO 27001 (information security)
• ISO 9001 (quality)
• ISO 14001 (environmental management)
• Cyber Essentials

These standards provide additional trust and assurance for compliance teams.

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The Benefits of Getting FCA Communication Right

Fewer Complaints and Better Outcomes

Customers who understand communications first time are less likely to complain or escalate issues. This supports Consumer Duty expectations and reduces operational strain.

Reduced Operational and Regulatory Risk

Clear workflows reduce human error. Audit-ready logs reduce exposure in FCA audits and dispute resolution.

Stronger Customer Trust

Reliable, timely, and accessible communication builds trust, especially in moments where clarity is essential.

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FAQs

What does the FCA require from customer communications?

Communications must be clear, fair, not misleading, accessible, and designed to support good customer outcomes.

How can financial institutions prove customers received a notice?

Through delivery logs, timestamped records, fallback processes, and documented templates.

Are email-only communications FCA compliant?

Not for all customers. Firms must support offline and vulnerable users and provide printed copies when required.

What is an audit trail and why does it matter?

An audit trail records every step of the communication journey, providing evidence that the firm met its obligations.

How can firms support vulnerable or offline customers?

By using multi-channel-intelligent-comms and maintaining print as an available channel.

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Key Takeaways

• The FCA expects clarity, fairness, accessibility, and proof of delivery.
• Digital-only communication is not compliant for many customers.
• Institutions need centralised templates and controlled approval processes.
• Multi-channel-intelligent-comms offer flexible routing and fallback options.
• Audit logs and record keeping are essential for Consumer Duty and SYSC compliance.
• A modern communication workflow protects both customers and institutions.

Ready to Strengthen Your FCA Compliance?

Discover how Micom helps financial institutions create compliant, verifiable communication workflows.

Explore Financial Services Solutions →

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References

• Financial Conduct Authority (2022). FG22/5: Consumer Duty Guidance, p.14.
• Financial Conduct Authority (2024). Communications Outcomes Review.
• Financial Conduct Authority (2015). FG15/4: Fair Treatment of Customers in Arrears, p.11.
• Ofcom (2024). Digital Exclusion Report, p.6.
• Ofcom (2024). Review of the Universal Service: Options for Change.
• FCA Handbook (2024). SYSC 3.2; MCOB/CONC requirements.
• EHRC (2022). Provision of Services