Introduction
The FCA issued a new publication in May 2025 on International Payment Pricing transparency outlining good and poor practices, to guide firms in enhancing transparency in international payment services and further embed Consumer Duty. The review focuses on how firms communicate pricing for international money remittances and cross-border payments involving currency conversion, aiming to ensure UK retail customers can make informed decisions.
Scope of the Publication
By highlighting good and poor practices, the FCA seeks to drive improvements in transparency and enable consumers to understand costs and compare options effectively. The publication applies to firms authorised under the Financial Services and Markets Act 2000, Payment Services Regulations 2017, and Electronic Money Regulations 2011 that offer international money remittance or cross-border payment services with currency conversion.
This includes banks, payment service providers and electronic money institutions providing these services to retail customers in the UK.
Good Practices
The FCA identified several good practices that promote transparency and support consumer understanding:
- Comprehensive Fee Breakdown: Clearly displaying all transaction costs, including fixed fees and exchange rate markups, before the consumer commits.
- Disclosure of Third-Party Fees: Proactively informing consumers about potential intermediary or recipient bank fees that may reduce the final amount.
- Highlighting Variable Fees: Explaining that fees may vary based on transaction specifics, avoiding misleading fixed-fee assumptions.
- Accessible Information: Making pricing details easy to find, requiring minimal navigation or scrolling on firms’ websites, with links to additional information for clarity.
These practices support the Consumer Duty’s requirement for clear, fair and non-misleading communication, helping consumers compare options and make informed choices.
Poor Practices
Conversely, the FCA also identified several firm practices that fall short of Consumer Duty expectations. While these may not always breach regulations, they indicate areas for improvement:
- Misleading “Zero Cost” Claims: Some firms advertise “zero cost” transfers by emphasising no fixed fees, while applying exchange rate mark-ups that obscure the true cost.
- Hidden Third-Party Fees: Failing to disclose intermediary or recipient bank fees upfront
- Inaccessible Pricing Information: Burying pricing details at the bottom of webpages or requiring multiple clicks to access them, hindering consumers’ ability to compare costs.
- Unclear Exchange Rate Details: Not explaining differences between the firm’s exchange rate and the reference rate
These poor practices undermine pricing transparency and can erode consumer trust and decision-making ability.
Next Steps for Firms
The FCA expects firms to take proactive steps to further align with Consumer Duty requirements and improve pricing transparency:
- Monitor and Review Communications: Firms are expected to regularly assess whether their pricing information enables consumers to understand costs and make informed decisions, as outlined by PRIN 2A.5.3R.
- Adopt Good Practices: Implement clear fee breakdowns, disclose third-party fees and ensure pricing information is accessible and prominent on their platforms.
- Address Poor Practices: Rectify misleading claims, such as “zero cost” marketing, and clarify exchange rate markups and variable fees.
- Support Vulnerable Consumers: Pricing information should be clear and accessible for all customers, including those with vulnerabilities, to prevent harm or confusion. Additional accessibility configurations on company websites should also be considered.
How Complyport Can Help
Complyport offers tailored compliance services to help firms meet regulatory landscape, including the evolving expectations under the Consumer Duty. Our services include:
- Consumer Duty Health check: Conducting full-scope review on your firm’s existing Consumer Duty framework and compliance with the Consumer Duty cross-cutting rules and four outcomes.
- Consumer Duty Monitoring and Reporting: Assessing your firm’s Consumer Duty monitoring metrics, data collection and benchmarking, and supporting the preparation of Consumer Duty management information reports.
- Consumer Duty Annal Board Report support: Supporting your Annual Consumer Duty Board Report preparations.
- Compliance Health check: Evaluating your firm’s existing compliance framework, systems and controls.
Get in Touch
Book a consultation with one of our Subject Matter Experts today to ensure your firm is aligned with the Consumer Duty best practices.
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