A crypto customer who leaves an account inactive may not expect a fee capable of running beyond £40,000 a year. Yet that was among the cases highlighted by the UK's Financial Conduct Authority in a 6 November account of its interventions against unfair financial-services contract terms. The regulator said it challenged a crypto firm's excessive storage charges, sometimes reaching that annual level; the business subsequently removed the provision and paid redress to affected consumers. The firm was not identified in the regulator's article, so its name and customer count cannot be inferred. The example is especially relevant to online brokers and wallet providers whose inactivity and custody rules can otherwise sit deep in lengthy account agreements.[1]
Sarah Montgomery, an FCA department head, set out how the Consumer Rights Act 2015 can operate alongside the financial regulator's own rules and Consumer Duty. The distinction is not semantic. A contract provision can be found unfair even when its wording was presented to a customer, and a consumer may be entitled to redress rather than merely having the clause removed from future terms. The FCA expects firms it challenges to amend or delete harmful provisions, stop applying them to existing customers, and remedy harm where appropriate. In some cases it can pursue an injunction or court-ordered redress.[1]
Verified record, scope and limitations
| Item | Evidence |
|---|---|
| Regulator publication | FCA blog of 6 November 2026; not a new rule commencement |
| Crypto storage fees | In some cases more than £40,000 a year; firm not named |
| Reported outcome | Storage-fee term removed and affected customers paid redress |
| Adviser complaint fee | £800 attempted complaint-handling charge; term changed |
| Insurance ambiguity | Twelve-hour delay clause clarified; £18,000 redress |
| Statutory powers | Consumer Rights Act 2015 plus FCA supervisory powers |
| Broker review focus | Fees, withdrawals, complaints, termination and actual customer outcomes |
Why disclosure alone does not make a contract fair
A second example involved a financial adviser that tried to charge £800 for the work of handling a complaint. The regulator considered that provision unfair because it could deter legitimate complaints; the adviser changed its contract. In a third case, an insurer clarified ambiguous twelve-hour travel-delay wording and paid £18,000 redress for wrongly rejected claims. A lender revised costs and cancellation terms before launch, illustrating that intervention can occur before customers are harmed. These are distinct examples, not evidence that every broker has charged such fees.[1]
For a CFD, FX or share broker, a useful review goes beyond making a fee visible. It should test when an inactivity fee starts; whether a balance can be depleted below reasonable custody costs; whether clients can complain or withdraw without disproportionate barriers; and whether conditions for promotions, copy-trading disconnections, margin liquidation and platform outages are comprehensible and fairly applied. The contractual entity, jurisdiction and product type still matter to the applicable law. The FCA's examples are not a new rule that began on 6 November, nor a universal declaration that inactivity fees are unlawful.[1]
The sharper business lesson concerns operational evidence. Management should be able to show not only what the agreement says but how the fee is triggered in the ledger, how complaints are handled, what frontline staff explain and whether outcomes expose a recurring customer harm. Consumer Duty monitoring and ordinary complaint records can identify problems before an enforcement dispute. A clause buried in a disclosure PDF is a poor defence if its practical operation is unfair.[1]
Sources & further reading
- The not-so-fine print: making consumer contracts fair Financial Conduct Authority · 6 Nov 2026 · Accessed 6 Nov 2026