Who it covers
The Duty applies to a firm's retail market business, and to financial promotions the firm communicates or approves that are addressed to or likely to be received by a retail customer.
A retail customer includes a prospective customer.
PRIN 3 sets out how the Duty applies.
Payment services and issuing electronic money count as regulated activities in the chapter.
Whether the Duty applies to your business is a question for your compliance team or a lawyer.
What it says about communications
The section on consumer understanding applies to all communications from a firm to its retail customers: before, during and after a sale, and in dealings that concern no particular product. It applies whatever the channel, electronic communications included.
A lifecycle email is a communication to a retail customer, so these rules apply to it when the Duty applies to the firm.
- A firm must support understanding, so that its communications meet the information needs of retail customers, are likely to be understood, and equip them to make effective, timely and properly informed decisions.
- A firm must communicate information in a way that is clear, fair and not misleading.
- A firm must communicate in good time, including at suitable points through the lifecycle of the product.
- A firm must satisfy itself that the channel enables the relevant information to be communicated and gives the customer time to review it.
- A firm should use plain language, make key information prominent, avoid unnecessary disclaimers and avoid so much detail that it gets in the way of a decision.
- A firm must tailor communications to the characteristics of its customers, including any vulnerability, the complexity of the product, the channel and the firm's own role.
Where appropriate, a firm must test communications before it sends them and regularly monitor their impact. When it finds an issue, it must investigate and correct it.
Section 2A.5 sets no test method and names no tool.
What it means for lifecycle email
- Give every email a job. A KYC reminder exists to get the ID check finished. Name the event that shows it worked, such as kyc.completed.
- Measure what people do next. Count who completed the step after the email. An open cannot show it; see Apple Mail and open rates.
- Compare before and after. Keep the wording of each version and what people did after it, so a change can be judged.
- Watch the response. Handbook guidance says that a notably different response than expected, a notably lower one included, to an email that asks for action suggests the email was not understood.
- Keep the record. Which version each person got and what they did next is the evidence you will want.
What Maqetin records
Publishing a change to a journey makes a new version, so before and after are separate dated records.
The step an email asks for lands on the profile as an event, next to the emails the person got.
Built-in holdout groups are planned; see email holdout testing.
Maqetin does not decide whether a communication meets the Duty. That judgement is the firm's.
Sources
- FCA Handbook, PRIN 2A.1: Application, checked 27 Oct 2026
- FCA Handbook, PRIN 2A.5: Consumer understanding, checked 27 Oct 2026