This is an illustrative scenario, not a description of a specific FCA enforcement case.
Monday
Compliance approves new fee wording. Version 8 is signed off.
Tuesday
The email template switches to version 8.
Wednesday
The customer portal still shows version 7.
Thursday
A batch of PDF statements is generated from another template. It also still contains version 7.
Same fee change. Three channels. Two versions live at once.
Where this shows up
A customer calls, confused.
The portal showed one fee. The email showed another.
Both came from live systems, but each channel updated on a different schedule.
The wording was approved once.
It did not go live once.
Why this happens
Email, portal content and generated documents often run through different systems and release cycles, so an approved change can reach one channel before another.
Which version was available on which channel, and when?
What the rules say
The FCA's Consumer Duty applies to retail customer communications regardless of the channel used and includes post-sale communications.
PRIN 2A.5.3R requires communications to support effective, timely and properly informed decisions and to be clear, fair and not misleading.
COBS 4.2.1R also requires communications and financial promotions within its scope to be fair, clear and not misleading.
Neither rule says every channel must update at exactly the same moment.
But if different channels show conflicting information, the firm needs to know what each one was presenting at that point in time.
How CommsPliant helps
CommsPliant gives connected channels one approved source instead of separate copies of the same wording.
Email, portal and document generation can use the same approved version, while the Evidence Vault records which version was generated and when.
The record shows what was generated, not whether the customer actually opened or read it.
Practical takeaway
One approved change should not leave customers seeing different versions across different channels.