Consumer Duty Statement
Last updated: July 26, 2026
The FCA Consumer Duty (Principle 12, PS22/9, effective July 2023) requires authorised firms to act to deliver good outcomes for retail customers across four outcome areas. While CardStack Technologies Ltd is not currently FCA-authorised, we voluntarily adhere to the spirit and letter of the Consumer Duty as a matter of good governance and in preparation for the regulation of cryptoasset activities under the Financial Services and Markets Act 2023. This statement sets out our commitments under each of the four Consumer Duty outcomes.
Outcome 01
Products & Services
FCA Requirement (PRIN 2A)
Products and services must be designed to meet the needs of a defined target market and must not be sold to customers outside that target market.
Our Commitments:
We maintain a documented Target Market Assessment (TMA) for each product feature on the platform.
Trading and investment features include appropriateness assessments to verify that users understand the risks before accessing high-risk products.
We do not market complex or leveraged products to users who have not completed the relevant appropriateness assessment.
Products are regularly reviewed against user outcomes data to identify and remediate harm.
Vulnerable users (including those showing signs of financial distress or impaired decision-making) are identified and directed to appropriate support.
Outcome 02
Price & Value
FCA Requirement (PRIN 2A)
The price of products and services must be reasonable relative to the overall benefits, and firms must not exploit consumers through excessive or obscured charges.
Our Commitments:
All fees and charges are disclosed clearly before any transaction. There are no hidden fees.
We publish a transparent fee schedule on our Pricing page that includes all platform fees, network fees, and spread information.
We conduct regular Value Assessments to ensure our fees are proportionate to the service provided.
We do not use dark patterns, psychological pricing pressure, or obscured unit costs to mislead users about total price.
We do not impose unfair early termination fees or lock-in clauses that prevent users from accessing a better deal.
Outcome 03
Consumer Understanding
FCA Requirement (PRIN 2A)
Communications must be clear, fair, and not misleading, and must support consumers in making informed decisions. Risk information must be prominent and not trivialised.
Our Commitments:
All risk warnings use plain language tested for readability. We target a Flesch Reading Ease score of ≥50 for compliance documents.
The FCA PS23/6 mandatory risk warning ("Don't invest unless you're prepared to lose all the money you invest") is displayed at the point of use on all financial features — not buried in footprints.
We do not use language that trivialises risk or implies guaranteed returns.
AI-generated content is clearly labelled and includes a disclaimer that it is not financial advice.
Educational content is reviewed for accuracy by our compliance team before publication.
We provide worked examples of fees, risks, and potential losses to support informed decision-making.
Outcome 04
Consumer Support
FCA Requirement (PRIN 2A)
Firms must provide support that meets the needs of customers across the lifecycle, including during difficult situations. Support must not be designed to deter, obstruct, or disadvantage consumers.
Our Commitments:
Our support team is available via email (support@cardstack.app) with a target first-response time of 24 hours on business days.
We have a formal written Complaints Procedure. Complaints are acknowledged within 5 business days and resolved within 8 weeks.
Account closure and withdrawal of funds are straightforward processes — we do not impose unreasonable barriers to exit.
We maintain a vulnerability policy to ensure users in vulnerable circumstances receive appropriate support and are not disadvantaged.
We do not use unreasonable hold times, automated-only support barriers, or deliberately confusing processes to deter legitimate requests.
Cross-Cutting Rules
In addition to the four outcomes, the Consumer Duty includes three cross-cutting behavioural rules (PRIN 2A.2) that apply to all our interactions with retail customers:
Act in Good Faith
We behave honestly and openly, disclose material information, and do not take advantage of information asymmetries between us and our users.
Avoid Foreseeable Harm
We proactively identify and mitigate foreseeable harms — including market risk, addiction to high-frequency trading, and vulnerability exploitation.
Support Financial Objectives
We provide tools, information, and support that genuinely help users achieve their financial objectives — not just our commercial objectives.
Complaints & Escalation
If you believe we have failed to meet any of the commitments in this statement, you can raise a complaint:
Email: complaints@cardstack.app
Subject: "Formal Complaint — Consumer Duty"
Response time: Acknowledgement within 5 business days; resolution within 8 weeks
Escalation: If unresolved after 8 weeks, you may refer to the Financial Ombudsman Service (FOS) — financial-ombudsman.org.uk
Note: The Financial Ombudsman Service may not have jurisdiction over all CardStack complaints as we are not currently FCA-authorised. However, we treat FOS referrals as binding on a voluntary basis for disputes where the FOS accepts jurisdiction.