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.
A deadline that forces real operational change
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:
- Fixed – unchangeable, version-controlled
- Findable – retrievable by the client at any time
- Viewable – identical in reproduction
- Provable – evidenced as delivered and accessible
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.
Why waiting until January is the real risk
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:
- shifted to digital-by-default
- put exception governance in place
- established a source of immutable, individually retrievable documents
- and embedded delivery/access evidence
…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.
The back-book challenge is no longer a technical inconvenience – it’s a compliance barrier
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.
Why digital-by-default is not simply a compliance requirement
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:
- reduced print and postage cost
- clearer MI and audit trails
- improved digital adoption
- fewer evidence hunts
- more consistent client experiences
As the industry moves firmly away from paper and PDF workflows, the firms that act early will benefit most – culturally, operationally, and commercially.
To learn more
Our full webinar goes deeper into these themes: the regulatory requirements, the durability test, the back-book challenge, and the evidence model supervisors will expect to see in practice.
🎥 Complete the form below to watch the on-demand webinar:
January 2026 is not far away – but the operational expectations begin the moment the rule takes effect. Firms that act now will cross the threshold ready. Those that wait risk starting the year already behind.