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The introduction of the Financial Conduct Authority’s PS25/13 Durable Medium rules marks a structural shift in how retail client disclosures must be delivered, evidenced, and governed. From 12 January 2026, digital becomes the default channel for regulated communications – with paper permitted only as a justified, audited exception.
This shift is more than a regulatory update. It is a fundamental rethink of what it means to “prove” that a client received, accessed, and could reproduce a communication exactly as issued. And crucially, firms cannot treat 12 January as the start of their transition. It is the point at which expectations crystallise, and evidence will be required.
One of the points raised in our recent webinar was that the most significant risk for firms is not the regulation itself – but the timing. PS25/13 was finalised in late October, and operational expectations apply by mid-January. This is one of the shortest lead times the industry has seen for a change of this scale.
As Hugh Evans, Commercial Director at Legado, noted during the session, the new rules require firms to demonstrate that every disclosure sent digitally is:
Sending PDFs by email – or storing content in portals without access evidence – will not meet these standards.
The “we sent it, therefore we complied” mindset no longer applies.
A recurring theme in the webinar was the misconception that firms can “prepare in January and comply in February”. The reality is that the moment PS25/13 goes live, firms must already have Durable Medium-compliant processes operational.
Those that have not:
…will begin their 2026 disclosure cycles from a position of non-compliance – before their first communication of the year is even issued.
As Joe Grace, Founder & CEO of Legado, put it:
“PS25/13 compliance is not a new system – it is a new discipline. Firms must close digital contact gaps and embed immutable, audit-ready evidence into their communications, and they must do it at pace.”
This framing reflects what many firms are now realising: January is not the moment to start acting. It is the moment supervisors may begin checking.
Perhaps the most difficult issue surfaced in the webinar was the back-book problem: the significant proportion of legacy client records with missing or unverified email addresses.
Under a digital-by-default model, this is no longer an operational annoyance – it is a direct barrier to evidencing Durable Medium compliance.
Without verified digital contact details, firms cannot demonstrate that clients could access their disclosures. This is a core failure point under the new rules.
The discussion highlighted that the most effective way to close these gaps is in-flow, during existing client interactions, not through large retrospective exercises. Firms need structured capture-and-verify loops: prompts in journeys, QR codes on print, SSO-verified updates, duplicate detection, background domain checks, and ongoing hygiene.
The takeaway: Back-book gaps cannot be left for later. They must be addressed as part of the move to digital-by-default – not after it.
What emerged in the conversation was that PS25/13 is not purely a regulatory hurdle – it is a catalyst for long-overdue change.
Firms modernising their communications under PS25/13 are already seeing:
As the industry moves firmly away from paper and PDF workflows, the firms that act early will benefit most – culturally, operationally, and commercially.