Consumer Duty: UK FCA raises the bar for international payment pricing transparency

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What’s the context for this latest FCA review?

On 1 May 2025, the FCA published the findings from its review of firms’ approach to pricing transparency when offering UK customers international money remittance and cross border payments. The specific focus was on whether firms’ communications gave clear pricing information before a transfer was initiated, and how firms interacted with reference rates. Other consumer-initiated payment services involving a currency conversion (eg purchasing travel money cards or withdrawing funds from an ATM) were not covered in the FCA’s findings.

This is one of the sector-specific priorities for its Consumer Duty work that the FCA confirmed last December.

The FCA has also recently published findings from another of these priorities, namely its review of how retail banks and building societies approach the treatment of customers in vulnerable circumstances that involve bereavement and power of attorney (PoA). Whilst the review focused specifically on the treatment of customers in vulnerable circumstances involving bereavement and use of PoAs, the themes highlighted by the FCA have potential relevance to all touchpoints with customers throughout the product/service lifecycle. Take a look at our article for more.

What were the FCA’s findings?

Overall the FCA found that some firms were clearly displaying the amount recipients would receive based on the amount remitted, along with the details of fees and charges. However, this was not always the case, making it challenging for consumers to compare prices and make informed decisions.

In particular, the following ‘good’ practices are emphasised:

• Transaction fees are clearly displayed: Firms should provide clear and full costs prior to the consumer committing to the transaction. The nature and amount of markups should be clearly explained and disclosed. For example, firms should not highlight the absence of a fixed fee as a ‘zero cost transaction’ despite charging a markup.
• Additional fees (eg intermediary bank fees) are displayed up front: Firms should proactively inform consumers that intermediary or recipient bank fees may affect the final payment amount, rather than leaving the consumer to discover this after the fees have been incurred.
• The fact that fees can vary is highlighted: The FCA includes some variable fee scenarios in its worked examples of good and poor practice (see below).
• Relevant information for consumers is easy to find: For example, consumers should not have to scroll to the bottom of the landing page or click elsewhere to find information about intermediary or recipient bank fees.

The FCA focused on firms' websites for its review, but it makes it clear that its findings apply regardless of the communication channel used.

The FCA also includes some worked examples of what it considers to be good and poor practice in relation to communication of fixed, variable and third party fees.

Authored by James Black and Virginia Montgomery.