Financial Disclaimer

Version 4.1 | Last updated 30 October 2026

Key points

This summary is part of this Disclaimer. The full terms follow.

• Outputs are estimates, not advice. Earnly's figures, categorisations, forecasts and insights are produced automatically by software from the data it can see. They are not financial, tax, accounting, investment or legal advice, and they are not regulated advice or guidance of any kind.
• Earnly does not file anything for you. Earnly does not submit returns, updates or accounts to HM Revenue and Customs or Companies House, is not HMRC-recognised Making Tax Digital software, and is not your tax agent.
• Know what is covered. Income Tax estimates use the rates for England, Wales and Northern Ireland. Scottish income tax rates are not supported: if you are a Scottish taxpayer, you must not rely on Earnly's Income Tax estimates. Some tax matters, such as capital gains and CIS, are not covered at all (section 8).
• Cash basis. Estimates are prepared on the cash basis by default, from your bank transactions.
• You must check before you act. Every tax figure carries the notice "Estimate only — not tax advice. Check before you file or pay." Before you file anything, pay any tax, apply for credit or make any other financial decision, you must check the relevant Outputs against your own records and take professional advice where appropriate.
• Outputs are for you only. Lenders, landlords, HM Revenue and Customs and anyone else must not rely on them.
• Your statutory rights are protected. If you are a Consumer, nothing in this Disclaimer affects your rights under the Consumer Rights Act 2015.

1. About this document

1.1 This Financial Disclaimer (this "Disclaimer") is issued by Earnly Limited, a private limited company registered in England and Wales (company number 16183799), whose registered office is at 41 New Cross Street, Swinton, Manchester, England, M27 4TU ("Earnly", "we", "us", "our").

1.2 This Disclaimer sets out the basis on which information and Outputs are made available to you through the Platform and the services delivered through it (the "Services"). It explains precisely what Outputs are and are not, which tax matters the Platform covers and does not cover, the assumptions and limitations on which Outputs rest, what you must do before relying on them, and where responsibility lies.

1.3 This Disclaimer applies to every user of the Platform. Section 11 also applies to any other person who obtains or seeks to rely on an Output.

1.4 This Disclaimer forms part of the Agreement. "Agreement" means the Terms and Conditions and the documents incorporated into them.

1.5 Order of precedence. If there is any conflict or inconsistency between this Disclaimer and another document forming part of the Agreement, the order of precedence in the "Documents forming part of the Agreement and order of precedence" clause of the Terms and Conditions applies. In summary, the Privacy Policy prevails on the processing of personal data, the Open Banking Consent Notice prevails on consent to the AIS and the use of Open Banking Data, the Complaints Procedure prevails on how we handle complaints, and the Terms and Conditions prevail over this Disclaimer. Nothing in any document forming part of the Agreement limits any right or protection which the law gives you and which cannot be excluded or limited by contract, including without limitation your statutory rights as a Consumer and your rights under data protection law.

2. Who this applies to

2.1 This Disclaimer applies to both Consumers and Business Users. Where a clause applies only to one class of user, it says so expressly. All other clauses apply to everyone.

2.2 Consumers. If you use the Platform wholly or mainly for purposes outside your trade, business, craft or profession (for example to understand your personal finances or your tax as an employee or individual investor), you are a Consumer. Clauses stated to apply only to Business Users do not apply to you, and nothing in this Disclaimer affects your statutory rights.

2.3 Sole traders, contractors and freelancers. If you use the Platform for your own trade, business or profession as an individual, you are a Business User. You are also an Individual, so you have rights under data protection law, and you are treated as a retail customer for the account information service described in the Open Banking Consent Notice.

2.4 Organisations and the individuals who act for them. If you use the Platform on behalf of a company, LLP, partnership or other organisation, that Organisation is a Business User. You, as the individual acting for it, must have authority to bind it to the Agreement.

3. Definitions

3.1 In this Disclaimer:

3.1.1 "Account" means your Earnly user account on the Platform. One Account can hold a personal (individual) profile and one or more companies.

3.1.2 "AIS" means the account information service described in the Open Banking Consent Notice.

3.1.3 "Business Day" means Monday to Friday, excluding bank holidays in England and Wales.

3.1.4 "Business User" means anyone using the Platform for a trade, business or profession, including without limitation a sole trader, contractor, freelancer, partnership, LLP, limited company or other organisation, and any individual (for example a director) acting on its behalf.

3.1.5 "Connected Account" means a bank or payment account which you have authorised to be connected to the Platform under the Open Banking Consent Notice.

3.1.6 "Consumer" means an individual acting wholly or mainly outside their trade, business, craft or profession.

3.1.7 "Individual" means any natural person who uses the Platform, whether as a Consumer or as a sole trader or other Business User.

3.1.8 "MTD" means Making Tax Digital, HM Revenue and Customs' requirements for keeping digital records and submitting information using compatible software.

3.1.9 "Open Banking Data" means the account details, balance and transaction data received in respect of a Connected Account.

3.1.10 "Organisation" means a company, LLP, partnership or other entity that is a Business User.

3.1.11 "Outputs" means estimates, categorisations, VAT treatment notes, confidence scores, forecasts, insights and any other automatically generated results produced by the Platform.

3.1.12 "Platform" means Earnly's responsive web application and website. If we release mobile apps, this Disclaimer applies to them too.

3.1.13 "Provider" or "Finexer" means Finexer Ltd.

3.1.14 "Relevant Decision" means any of the following: filing or submitting any return, update, declaration, registration or accounts with HM Revenue and Customs, Companies House or any other authority; paying or deciding not to pay any tax, National Insurance, VAT or payment on account; declaring a dividend, taking drawings or paying remuneration; applying for or entering into any loan, mortgage, overdraft, finance, lease or tenancy; giving any figure to a lender, landlord, insurer, investor, accountant or public authority; and entering into any other financial commitment.

3.2 "Including" and similar words are to be read as "including without limitation". Headings do not affect interpretation.

4. Regulatory status

4.1 The following disclosure applies to the account information services made available through the Platform:

Earnly Limited (FRN 1058277) is registered on the Financial Services Register as an agent of Finexer Ltd, which is authorised and regulated by the Financial Conduct Authority under the Payment Services Regulations 2017 (Firm Reference Number 925695) for the provision of account information services. You can check this on the Financial Services Register at register.fca.org.uk. Earnly is not itself authorised by the Financial Conduct Authority. Earnly does not provide payment initiation services, cannot initiate payments or move money, and never receives, sees or stores your online banking credentials.

4.2 Earnly does not hold client money. The tax, accounting and analytical features of the Platform, and all Outputs, are provided by Earnly in its own right and are not regulated by the Financial Conduct Authority.

4.3 The Open Banking Consent Notice explains the account information service, your consent and your rights in relation to it.

5. No advice and no advisory relationship

5.1 Earnly provides information and technology. Earnly does not provide financial advice, tax advice, accounting advice, investment advice, pensions advice, debt advice or legal advice.

5.2 No Output, and nothing on the Platform, is or should be treated as:

5.2.1 advice on investments, a personal recommendation, or any other regulated advice within the meaning of the Financial Services and Markets Act 2000 or the Financial Conduct Authority's rules;

5.2.2 targeted support, simplified advice or guidance provided under any regime of the Financial Conduct Authority, or guidance from a government-backed guidance service;

5.2.3 tax advice or an opinion from a qualified tax adviser or accountant; or

5.2.4 an invitation or inducement to engage in investment activity.

5.3 Earnly does not:

5.3.1 act as your accountant, tax adviser, bookkeeper, auditor or tax agent;

5.3.2 act as your agent in dealings with HM Revenue and Customs, Companies House or any other authority;

5.3.3 arrange, advise on, deal in or make arrangements with a view to transactions in investments, or carry on any other regulated activity; or

5.3.4 provide any credit, credit broking, debt counselling or debt adjusting service.

5.4 No fiduciary, advisory, trustee or professional-client relationship arises between you and Earnly because of your use of the Platform, any Output, or any communication from Earnly, its staff or its contractors. Help content (including the pre-written content in the "Ask Earnly" preview), worked examples, insights and support responses are general information and are not advice on your circumstances. Earnly's only agency relationship is the one with Finexer described in section 4, which does not make Earnly your agent.

5.5 If you need advice on your circumstances, you should obtain it from a suitably qualified accountant, tax adviser, financial adviser or lawyer. If you are a Business User, you must do so before taking any Relevant Decision for which professional judgement is reasonably required.

6. What Outputs are and are not

6.1 What Outputs are. Outputs are automatically generated estimates and proposals. They are produced mainly by rules-based software running within Earnly's own systems. Where those rules cannot categorise a transaction, a third-party AI model may suggest a category from a cleaned merchant name and amount only. The AI Policy explains both. Each Output is produced from:

6.1.1 the Open Banking Data and other data available to the Platform at the time it is produced;

6.1.2 any information and corrections you have entered;

6.1.3 the tax rates, thresholds and rules loaded into the Platform at that time; and

6.1.4 the scope limits in section 8 and the assumptions in section 9.

6.2 What Outputs are not. Outputs are not, and you must not treat them as:

6.2.1 a tax return, a self assessment calculation, a corporation tax computation, a VAT return or any other computation prepared for filing;

6.2.2 a statement or confirmation of your actual tax liability or of any amount owed to or by HM Revenue and Customs;

6.2.3 statutory accounts, management accounts or any other financial statement prepared to a recognised accounting standard;

6.2.4 digital records kept for MTD purposes, or an MTD quarterly update or final declaration;

6.2.5 a valuation, an audit, an assurance report or a professional opinion of any kind; or

6.2.6 evidence of income, affordability or creditworthiness for any lender, landlord or other third party.

6.3 Outputs will differ from professional work. An Output will not necessarily match a return or accounts prepared by a qualified accountant or tax adviser with access to your complete records and circumstances. Differences should be expected and may be material.

6.4 Outputs change. Outputs may change, sometimes materially, as new data is received, as you make corrections, as rates and rules are updated, and as the Platform is developed. An Output is accurate, if at all, only as at the time it is produced.

6.5 On-screen notice. Beside every tax figure, the Platform displays the notice "Estimate only — not tax advice. Check before you file or pay." Where the Platform shows an amount of tax with a payment or filing date, the amount is an estimate and the date is the statutory deadline that would normally apply. Neither is a confirmation of what you owe or when.

7. Making Tax Digital, HMRC and Companies House

7.1 MTD for Income Tax. Since 6 April 2026, MTD for Income Tax has applied to sole traders and landlords with qualifying income over £50,000. From 6 April 2027 it applies to those with qualifying income over £30,000. If MTD applies to you, you must keep digital records and make submissions to HM Revenue and Customs using HMRC-recognised compatible software. MTD for VAT applies to all VAT-registered businesses.

7.2 Earnly is not MTD software. Earnly is not HMRC-recognised MTD compatible software, does not keep digital records for MTD purposes and does not make any MTD submission. Using the Platform does not satisfy any MTD obligation. If MTD applies to you, you must use compatible software or an agent who uses it.

7.3 No filing. Earnly does not file, submit or send any return, update, declaration, registration, confirmation statement or accounts to HM Revenue and Customs, Companies House or any other authority on your behalf.

7.4 Public data only. The Platform retrieves company profile information from the Companies House public register when you search for a company, and checks whether a VAT number is valid using HM Revenue and Customs' public VAT number checker. These checks read public information only. They do not involve any submission to, or any account with, either authority, and a valid result does not confirm that any VAT treatment is correct.

7.5 Not your agent. Earnly is not your tax agent and is not authorised to act for you with HM Revenue and Customs. Earnly will never contact HM Revenue and Customs on your behalf.

7.6 You remain fully responsible for registering for, complying with and meeting all deadlines under self assessment, MTD, VAT, PAYE, corporation tax, Companies House and any other regime that applies to you.

8. What the tax features cover

8.1 Supported estimates. The Platform produces estimates of the following, and nothing else:

8.1.1 Income Tax, National Insurance, dividend tax and savings tax for Individuals, using the rates, bands and allowances for England, Wales and Northern Ireland for the current tax year;

8.1.2 Corporation Tax for companies, applying the main rate, the small profits rate, marginal relief and the reduction of the limits for associated companies, based on the number of associated companies you record;

8.1.3 VAT for the standard scheme and the flat rate scheme. If you record that you use the cash accounting scheme or the annual accounting scheme, the Platform records that choice, but its VAT estimates are still prepared on the standard scheme basis, so they may not match the amounts or the timing of what you owe under the scheme you use; and

8.1.4 Employer PAYE and National Insurance contributions, estimated from payroll transactions that appear in your Connected Accounts or that you record.

8.2 Scottish taxpayers. Scottish income tax rates and bands are not supported. If you are a Scottish taxpayer, the Platform's Income Tax estimates will be calculated using the wrong rates and bands and will be wrong, and you must not rely on them. The Platform warns Scottish taxpayers of this. National Insurance, Corporation Tax and VAT estimates are not affected by Scottish taxpayer status.

8.3 Not supported. The Platform does not estimate, take into account or give any indication about:

8.3.1 capital gains tax or any chargeable gain;

8.3.2 the Construction Industry Scheme;

8.3.3 IR35 or the off-payroll working rules, including whether any engagement is inside or outside IR35;

8.3.4 partnership returns or the allocation of partnership profits;

8.3.5 trusts or the tax affairs of trustees or beneficiaries;

8.3.6 non-residence, split-year treatment, the remittance basis or any foreign income or double taxation relief; or

8.3.7 research and development relief or expenditure credits.

If any of these applies to you, Outputs will be incomplete and may be materially wrong, and you must take professional advice.

8.4 Rate updates. Earnly updates the tax rates, bands, allowances and thresholds in the Platform within 30 days of any change taking effect. Until a change has been loaded, Outputs use the previous figures. A change announced in a Budget or other statement is not reflected until it has taken effect and been loaded.

9. Assumptions and limitations

9.1 Every Output rests on assumptions and is subject to limitations. Unless you have recorded otherwise in the Platform, they include the following.

9.1.1 Visibility. The Platform sees only Connected Accounts and data you have entered or uploaded (including receipt images). Income, expenditure, assets and liabilities held elsewhere are invisible to it, including without limitation other bank accounts, cash, employment income, pensions, investments, rental income and income of a spouse or civil partner.

9.1.2 Cash basis. By default, Outputs are produced on the cash basis, using the dates on which money enters and leaves your Connected Accounts. They do not reflect invoices issued or bills received but not yet paid, stock, accruals, prepayments or depreciation. The accruals basis can produce materially different figures. Companies must calculate Corporation Tax using accounts prepared on the accruals basis, so a company's actual Corporation Tax computation may differ materially from the Platform's estimate.

9.1.3 Tax year and residence. Outputs assume that you are UK resident for tax purposes, that the UK tax year runs from 6 April to 5 April, that a company's financial year follows the period you have recorded, and, for Income Tax, that you are not a Scottish taxpayer (clause 8.2).

9.1.4 Allowances and reliefs. Outputs apply the standard personal allowance (including its reduction for income over £100,000), the dividend allowance and the personal savings allowance. They do not apply any other allowance, relief or deduction unless the Platform expressly shows that it has done so.

9.1.5 Unrecorded items. Cash transactions, transactions on unconnected accounts, mileage, use of home, capital allowances, year-end adjustments, disallowable items and private-use apportionments are not captured unless you record them.

9.1.6 Categorisation. Transactions are categorised automatically by rules, with a VAT treatment note and a confidence score from 0 to 100. Where the rules cannot assign a category, an AI model may suggest one, labelled "AI suggested". An AI suggested category is never marked as reviewed automatically and can be wrong, because the model sees only a merchant name and an amount. Categorisation is a proposal, not a determination. It may be wrong even where the confidence score is high, and transactions scoring 95 or more are marked as reviewed automatically without you having checked them. Where you correct a categorisation, your correction prevails. The AI Policy explains how categorisation and confidence scores work.

9.1.7 VAT. VAT treatment notes are indicative only. They do not determine the correct VAT treatment of a supply and do not take account of partial exemption, the reverse charge, margin schemes, place-of-supply rules, the VAT registration and deregistration thresholds, or the cash accounting and annual accounting schemes (clause 8.1.3).

9.1.8 Personal circumstances. Outputs do not take account of matters the Platform does not know, including without limitation other income, employment, jointly held assets, residence and domicile, losses brought forward, pension contributions, Gift Aid, student loan repayments, the High Income Child Benefit Charge, or any other matter you have not recorded.

9.1.9 Company matters. Outputs for limited companies do not take account of directors' loan accounts, whether a dividend is lawful (including without limitation whether distributable reserves are available), group relief or research and development relief, and take account of associated companies only to the extent you record them.

9.1.10 Third-party data. Outputs depend on data supplied by Finexer and your bank, which may be delayed, incomplete, duplicated or inaccurate, and on the accuracy of the information you enter.

9.2 Forecasts. Forecasts, projections and other forward-looking Outputs are inherently uncertain. They are based on historic data and on assumptions about future events which may not occur. Past patterns are not a reliable indicator of future income, expenditure or tax. No forecast is a promise, guarantee or assurance of any outcome.

10. Your verification duty and responsibilities

10.1 Verification before any Relevant Decision. Before you take any Relevant Decision, you must:

10.1.1 check every Output on which the decision depends against your own records, bank statements, invoices and receipts;

10.1.2 check that all relevant income and expenditure is included, including anything the Platform cannot see;

10.1.3 check that the matter is within the scope of section 8 and that none of the unsupported matters in clause 8.3 applies;

10.1.4 review and, where needed, correct every relevant categorisation and VAT treatment note, including those marked as reviewed automatically; and

10.1.5 obtain professional advice where the decision requires professional judgement or where you are unsure.

10.2 Your responsibilities. You remain responsible for:

10.2.1 your tax position and your compliance with all tax and company law obligations;

10.2.2 keeping complete and accurate books, records and supporting documents, and retaining them for the periods required by law. Earnly does not keep your records for you, and deletes Open Banking Data as described in the Open Banking Consent Notice;

10.2.3 the preparation, accuracy and timely submission of every return, update, declaration, registration and filing;

10.2.4 calculating and paying, on time, all tax, National Insurance, VAT and other amounts due, including payments on account; and

10.2.5 keeping the data you enter accurate and up to date, including your tax residence, VAT scheme and associated companies.

10.3 Earnly's reliance on your data. Earnly is entitled to rely on the data you enter and the corrections you make as accurate and complete. Earnly does not check them.

10.4 Using the Platform does not transfer to Earnly any legal, regulatory, financial or tax responsibility of yours.

11. Use of Outputs by other people

11.1 For your use only. Outputs are made available to you alone, for your own use. They are not prepared for, and must not be relied on by, any other person, including without limitation:

11.1.1 HM Revenue and Customs, Companies House or any other public authority;

11.1.2 any lender, mortgage provider, mortgage broker, credit provider or credit reference agency;

11.1.3 any landlord, letting agent or tenant referencing service;

11.1.4 any insurer, investor, purchaser or business counterparty; and

11.1.5 your accountant or other adviser, except as an unverified starting point for their own work.

11.2 No duty to third parties. Earnly owes no duty of care to, and accepts no liability to, any third party who obtains or relies on an Output, whether or not Earnly knew or ought to have known that the Output might be disclosed to that person.

11.3 If you share an Output. If you share an Output with anyone, for example by sending them a CSV export, you must tell them that it is an unverified estimate produced by software and that they must not rely on it. You must not present any Output as verified, professionally prepared or an assurance of any kind.

11.4 If you are a Business User: you are responsible for any claim brought against Earnly by a third party to whom you, or anyone acting for you, supplied an Output presented as verified, professionally prepared or an assurance, or used to mislead, to the extent set out in the "Indemnity" clause of the Terms and Conditions.

11.5 If you are a Consumer: you give no indemnity under this Disclaimer.

12. Responsibility and liability

12.1 What is never excluded. Nothing in this Disclaimer excludes or limits liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for anything else which cannot lawfully be excluded or limited.

12.2 If you are a Consumer:

12.2.1 you have statutory rights under the Consumer Rights Act 2015, including without limitation the rights that digital content must be of satisfactory quality, fit for a particular purpose made known to Earnly, and as described (sections 34 to 47), and that services must be performed with reasonable care and skill and in line with what Earnly has said about them (sections 49 to 57). Nothing in this Disclaimer excludes or limits those rights;

12.2.2 this Disclaimer describes what the Services are. It is not intended to reduce Earnly's responsibility for the Services as described;

12.2.3 Earnly is responsible for loss or damage you suffer which is a foreseeable result of Earnly breaching the Agreement or failing to use reasonable care and skill. Earnly is not responsible for loss which is not foreseeable; and

12.2.4 where your loss is caused partly by your own failure to follow section 10, Earnly's responsibility is reduced to the extent that your failure contributed to the loss.

12.3 If you are a Business User: the exclusions and limitations in the "Limitation of liability" clause of the Terms and Conditions apply to this Disclaimer, and the Platform and Outputs are provided "as is" and "as available", with implied terms excluded as set out in the Terms and Conditions. Without limiting that clause, and subject to clause 12.1, Earnly is not liable to a Business User, whether in contract, tort (including negligence), breach of statutory duty, misrepresentation or otherwise, for:

12.3.1 any penalty, interest, surcharge, determination, assessment or additional tax charged by HM Revenue and Customs or any other authority;

12.3.2 any cost of professional advice, enquiry, investigation, correction, amended return or voluntary disclosure;

12.3.3 any loss arising from a Relevant Decision taken without carrying out the verification required by clause 10.1;

12.3.4 any loss arising from reliance on an Output about a matter outside the scope of section 8, or on an Income Tax estimate by a Scottish taxpayer;

12.3.5 any inaccuracy, incompleteness, delay, corruption or unavailability of data originating from Finexer, your bank or any other third party other than Earnly's own subcontractors;

12.3.6 any financial, commercial or tax decision taken by you or by any third party; or

12.3.7 loss of profit, revenue, goodwill, anticipated savings, business opportunity or contract, whether direct or indirect, or any loss or corruption of data except as provided in the "Limitation of liability" clause of the Terms and Conditions.

12.4 If you are a Business User: you acknowledge that you do not rely on any Output, or on any statement by or on behalf of Earnly not set out in the Agreement, as a substitute for your own judgement or professional advice, and that the allocation of risk in this section is reasonable having regard to the nature and price of the Services (which are free of charge during early access), the availability to you of professional advice and your own records, and the verification duty in section 10. This acknowledgement does not exclude liability for fraudulent misrepresentation.

12.5 Liability cap. Earnly's total liability is subject to the "Limitation of liability" clause of the Terms and Conditions.

13. Changes to this Disclaimer

13.1 Earnly may change this Disclaimer only to reflect a change in the law, in regulation or regulatory guidance, or in tax rules; to reflect a change in the Platform or the Services; or to make the Disclaimer clearer.

13.2 Earnly will give you at least 30 days' notice of any material change, by email and in the Platform, before it takes effect. If you do not agree to a material change, you may end your Agreement free of charge before the change takes effect, as described in the "Changes to the Agreement" clause of the Terms and Conditions.

13.3 If a material change is adverse to you, Earnly will ask you to accept it positively before it applies to you. Continued use alone will not be treated as acceptance of a material adverse change.

13.4 Earnly may make minor changes which do not adversely affect you without notice, such as correcting typographical errors, updating the statutory figures in section 7 to reflect the law, or adding a newly supported tax feature to section 8. The current version is always available in the Platform and at https://earnly.co.uk/legal/financial-disclaimer.

14. Complaints

14.1 If you are unhappy with the Platform or an Output, you can complain by email to complaints@earnly.co.uk, using the online form at https://earnly.co.uk/complaints, in the Platform through Settings → Help, or by post to the address in section 16. Complaints are handled under the Complaints Procedure, which forms part of the Agreement. We acknowledge complaints within 2 Business Days and send a final response within 8 weeks. Complaints about the account information service are handled as described in the complaints section of the Open Banking Consent Notice. Complaints about personal data are handled under the Privacy Policy.

15. General

15.1 Each provision of this Disclaimer operates separately. If any provision is found by a court or other competent authority to be unlawful, invalid or unenforceable, the remaining provisions continue in force.

15.2 This Disclaimer is governed by the law of England and Wales. If you are a Business User, the courts of England and Wales have exclusive jurisdiction. If you are a Consumer, you may bring proceedings in the courts of England and Wales or, if you live in Scotland or Northern Ireland, in the courts of the part of the United Kingdom where you live, and the mandatory consumer protection law of that part of the United Kingdom applies to you.

16. Contact

Earnly Limited
41 New Cross Street
Swinton
Manchester
England
M27 4TU

• General support: support@earnly.co.uk
• Complaints: complaints@earnly.co.uk