The FCA’s Policy Statement PS 25/13 represents a meaningful evolution in how regulated firms must deliver information to retail clients. By reframing the definition of a “durable medium,” the FCA has signalled a clear expectation: digital should now be the assumed default, with paper available on request rather than the starting point.
This shift reflects how consumers already interact with financial services – through apps, portals, emails, and secure digital tools. The FCA recognises that digital formats can meet the essential durable-medium criteria: they allow clients to store information long-term, retrieve it when needed, and reproduce it unchanged. In most cases, digital communication is not just equivalent to paper – it is more practical, traceable, efficient and accessible.
But with this shift comes responsibility. Firms must still ensure that clients who prefer paper can easily request it. And digital delivery must be durable in a regulatory sense – not simply convenient. That means thinking carefully about accessibility, record-keeping, audit trails, and how systems present and preserve key documents.
Why This Matters for Firms Now
Many organisations are already delivering client documents digitally, but not always in a way that meets durable-medium standards. PS 25/13 requires firms to review whether their current systems truly allow clients to store and access personalised information over the long term – and whether the firm can evidence this with confidence.
This turns what used to be a technical back-office question into a strategic consideration that affects marketing, CRM, compliance, operations, and client experience.
How Legado Supports Digital-First Durable Medium Delivery
This is where Legado provides a decisive advantage. Legado’s secure digital infrastructure is designed specifically to support durable-medium communications in a compliant, intuitive, and future-proof way.
With Legado, firms can confidently make digital the default because:
- Documents remain immutable, accessible and stored long-term within a secure client environment.
- Clients receive a smooth, transparent digital experience, with all key information in one place.
- Firms have strong audit-ready evidence of delivery, access, and retention.
The result is a compliant digital-first approach that reduces paper dependence, strengthens operational efficiency, and enhances the overall client journey – while meeting the expectations set out in PS 25/13.
Join Our Webinar
We’ll be exploring these regulatory changes in depth and demonstrating how Legado enables fully compliant digital durable-medium delivery.
👉 Register here
Join us, on Wednesday 3rd December, as we discuss what PS 25/13 means in practice and how firms can adopt a digital-first durable-medium strategy that not only satisfies the FCA but genuinely strengthens client communications.