Treating Customers Fairly
Last updated 30 October 2026
Version 4.2 | Last updated 30 October 2026
1. About this statement
1.1 This statement is published by Earnly Limited, a private limited company registered in England and Wales (company number 16183799), registered office 41 New Cross Street, Swinton, Manchester, England, M27 4TU ("Earnly", "we", "us", "our"). It explains the standards of fair treatment we apply to everyone who uses the Earnly platform at earnly.co.uk and the Earnly web application (the "Platform"), and what you can expect from us.
1.2 This statement is an informational document under the "Documents forming part of the Agreement and order of precedence" clause of the Terms and Conditions (https://earnly.co.uk/legal/terms-and-conditions). It is not incorporated into the Agreement and does not create contractual rights in addition to those in the Terms and Conditions and the documents incorporated by them. It summarises commitments that are set out in full in those documents, and it is supported by Earnly's internal Consumer Duty and Treating Customers Fairly Policy, which our staff and contractors must follow. If this statement and an incorporated document differ, the incorporated document applies.
1.3 Nothing in this statement limits any right you have under the Agreement or under law or regulation, including your statutory rights if you are a Consumer.
1.4 Words with capital letters have the meanings given in the "Definitions and interpretation" clause of the Terms and Conditions. In particular:
1.4.1 "Consumer" means an individual acting wholly or mainly outside their trade, business, craft or profession;
1.4.2 "Business User" means anyone using the Platform for a trade, business or profession, including a sole trader, contractor, freelancer, partnership, LLP, limited company or other organisation, and any individual (for example a director) acting on its behalf;
1.4.3 "Individual" means any natural person who uses the Platform, whether as a Consumer or as a sole trader or other Business User;
1.4.4 "Organisation" means a company, LLP, partnership or other entity that is a Business User;
1.4.5 "Provider" means Finexer Ltd, which provides the account information service through the Platform; and
1.4.6 "Business Day" means Monday to Friday, excluding bank holidays in England and Wales.
2. Who this statement applies to
2.1 This statement applies to everyone who uses the Platform or contacts us about it: Consumers, sole traders, contractors, limited company directors and the Organisations they act for, and people on our website waitlist.
2.2 If you connect a bank account. The account information service you receive when you connect a bank account is a regulated payment service provided by the Provider, with Earnly acting as its agent. If you are a Consumer, a sole trader or another micro-enterprise (fewer than 10 employees and annual turnover or balance sheet total of €2 million or less), or a charity with annual income below £1 million, you are a "retail customer" of the Provider, and the Financial Conduct Authority's Consumer Duty applies to that service. We follow the Consumer Duty standards in everything we do for you as the Provider's agent.
2.3 Everyone else, and every other feature. We apply the same standards voluntarily to every user and to every part of the Platform, including Business Users who are not retail customers and features that are not part of the account information service, such as tax estimates and transaction categorisation.
3. Our regulatory status
3.1 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.
3.2 Earnly does not give financial, tax, accounting, investment or legal advice. Earnly does not file anything with HMRC or Companies House, is not HMRC-recognised Making Tax Digital software and is not your tax agent.
3.3 Earnly is registered with the Information Commission (ICO) under registration number ZB962890 and is the controller of the personal data it processes to provide the Platform, as explained in the Privacy Policy (https://earnly.co.uk/legal/privacy).
4. Our commitments
4.1 We will:
4.1.1 act in good faith towards you, which means being honest and open with you and never exploiting a lack of knowledge, a behavioural bias or difficult circumstances;
4.1.2 take reasonable steps to avoid causing you foreseeable harm through how the Platform is designed, how we communicate, how we support you and how we handle your data; and
4.1.3 help you understand your income, spending and estimated tax position, within the limits of what the Platform does.
4.2 The harms we specifically design against include: relying on a tax estimate that turns out to be wrong; a Scottish taxpayer relying on an income tax estimate calculated at the rates for England, Wales and Northern Ireland; filing with HMRC on the basis of figures that have not been checked; reading a categorisation confidence score as a probability of being correct; believing that Earnly is an accountant or files returns; your data being used for something you did not ask for; and losing access to your bank data because a consent expired without warning.
5. Who the Platform is for
5.1 The Platform is designed for people in the United Kingdom, aged 18 or over, who want to understand their income, spending, cash flow and estimated tax position and who will check the figures before relying on them. This includes Consumers managing their personal finances (for example employees with side income or landlords managing their personal tax affairs), sole traders and contractors, limited company directors, and small companies established in the United Kingdom acting through their directors.
5.2 The Platform is not designed for, and we do not market it to:
5.2.1 anyone looking for tax, accountancy, legal or investment advice, or a substitute for it;
5.2.2 anyone who intends to file a tax return or Making Tax Digital update using the Platform's figures without checking them;
5.2.3 accountants, bookkeepers or others acting for clients, because team and accountant access is not offered;
5.2.4 people whose tax affairs depend on matters the Platform does not support, namely capital gains, the Construction Industry Scheme, IR35 determinations, partnership returns, trusts, non-residence and research and development relief;
5.2.5 Scottish taxpayers who want income tax estimates, because Scottish income tax rates are not supported (Scottish taxpayers may use the other features, and the Platform warns them not to rely on income tax estimates);
5.2.6 people resident outside the United Kingdom, Organisations not established in the United Kingdom, or anyone wishing to connect non-UK accounts; and
5.2.7 anyone under 18.
5.3 When you sign up, you must confirm that you are 18 or over and resident in the United Kingdom (or, for an Organisation, established in the United Kingdom), as set out in the "Eligibility and user status" clause of the Terms and Conditions.
6. Products and services designed for your needs
6.1 Before we release a new feature, a material change to an existing feature, a price change or a material change to how we communicate with you, our Director reviews it against a fair treatment checklist covering who it is for, what could go wrong, whether it will be understood, whether it is accessible, and whether it affects your bank connection or your data. We do not release features that cannot meet the standards in this statement.
6.2 Transaction categorisation is rules-based and runs within Earnly's own systems. Only where our rules, your own rules and the anonymised merchant table cannot categorise a transaction, we ask Anthropic's Claude Haiku 4.5 model to suggest a category. We send it only a cleaned merchant name and the amount, never payments to or from individuals, person-to-person payments or transfers between your own accounts, and never your name, account details, bank descriptions, references or dates. Anthropic is contractually prohibited from training on that data. The suggestion is labelled "AI suggested" and is never marked as reviewed automatically. You can change any category at any time, and your correction always takes precedence. If we introduce a new AI provider or send an AI model any further data, we will first complete a data protection impact assessment, use only a provider that is contractually prohibited from training on your data, give you 30 days' notice and update the AI Policy (https://earnly.co.uk/legal/ai-policy) and the Sub-processor List (https://earnly.co.uk/legal/sub-processors).
6.3 We make no solely automated decisions that have legal or similarly significant effects on you. A person always reviews any decision to suspend or close an Account.
6.4 If we find an error that has caused, or could cause, you harm (for example an error in a tax rate or calculation), we will correct it, tell affected users where appropriate and consider putting things right, whether or not anyone has complained. We update tax rates within 30 days of a change taking effect.
7. Price and fair value
7.1 The Platform is free of charge during Early Access. No fees are payable and we do not collect payment card details.
7.2 Even though the Platform is free, we review at least once a year whether it offers you fair value, taking into account the data you share, the time you spend checking figures and the limits of what the Platform does. Your bank data is used only to provide the service you asked for. It is never sold and never used for marketing.
7.3 If we introduce paid plans, the "Price, Early Access and paid plans" clause of the Terms and Conditions applies. In summary:
7.3.1 we will give at least 30 days' notice, and you will not be charged unless you actively choose a paid plan and accept its price at that time;
7.3.2 we will show the total price including VAT, how often you will be billed, the renewal date and any minimum term before you commit, with no hidden or later-added charges;
7.3.3 we will not use fake urgency, countdown timers, pre-ticked boxes or misleading reference prices;
7.3.4 we will give at least 30 days' notice of any price change, and you may cancel free of charge before it takes effect;
7.3.5 you may cancel at any time, online, as easily as you subscribed, with effect from the end of the current billing period;
7.3.6 if we end your paid plan without cause, we will refund the unused part of the billing period; and
7.3.7 if you are a Consumer, you also have a 14-day right to cancel, as set out in the "Your right to cancel if you are a Consumer" clause of the Terms and Conditions.
8. Clear communication
8.1 Everything we say about the Platform, including our website, onboarding, consent screens, in-app text, emails, help content and support replies, must be clear, fair and not misleading.
8.2 In particular:
8.2.1 every tax figure on the Platform is an estimate. Beside every tax figure we show the caveat "Estimate only — not tax advice. Check before you file or pay." The Financial Disclaimer (https://earnly.co.uk/legal/financial-disclaimer) explains the assumptions and limits that apply, including that estimates use the cash basis from your bank transactions and the current tax year's rates;
8.2.2 you must check any figure before you file with HMRC, pay tax, make a statutory declaration or rely on it for a lending or other financial decision, as set out in the "Your data, Outputs and your duty to verify" clause of the Terms and Conditions;
8.2.3 a categorisation confidence score shows how strongly a matching rule applies. It is not a probability that the category is correct;
8.2.4 we never describe Earnly as an accountant, a tax adviser or a tax return service, or claim that our figures are approved by HMRC or that Earnly is authorised by the FCA;
8.2.5 "Ask Earnly" is a preview containing pre-written help content. It does not analyse your data and is not an AI assistant; and
8.2.6 before you connect a bank account, we explain in plain language what Open Banking is, what data is shared, how long the consent lasts and how to withdraw it, as set out in the Open Banking Consent Notice (https://earnly.co.uk/legal/open-banking-consent-notice).
8.3 We test key communications, such as onboarding, consent, estimates and their caveats, and how to complain, with people from our target users before we release them, and we change them if they are not understood.
9. Your bank connection
9.1 When you connect a bank account through the Provider, we receive account details, balances and transactions only. We cannot make payments or move money.
9.2 On first connection we import up to 5 complete UK tax years plus the current tax year of history. Your data refreshes automatically about every 15 minutes while you are using Earnly, and whenever you open the app or select Refresh.
9.3 Your consent lasts 90 days and must be reconfirmed at least every 90 days. We warn you in the app (from 14 days, and again from 3 days, before expiry) and by email 14 days, 7 days and 1 day before expiry. Reconfirming is quick, and we will never pressure you to reconnect.
9.4 You can withdraw your consent at any time, free of charge and without giving a reason, by selecting Disconnect in Settings → Integrations, through your bank, or by emailing support@earnly.co.uk. Disconnecting in the app revokes the consent with the Provider and stops access immediately.
9.5 When a consent is withdrawn, expires without being reconfirmed or is disconnected, or when you close your Account, a 30-day cooling-off period applies, during which you can reactivate the connection or your Account, in which case your data is kept. Otherwise we delete the Open Banking Data at the end of that period, except for the minimal records listed in the Data Retention Policy (https://earnly.co.uk/legal/data-retention-policy), which contain no transaction data. You can export your transactions as a CSV file at any time, including during the cooling-off period.
10. Support when you need it
10.1 Support is provided by email at support@earnly.co.uk, Monday to Friday, 9:00 to 17:30 UK time, excluding bank holidays in England and Wales. We aim to reply within 2 Business Days. These are targets, not contractual service levels.
10.2 We do not have a telephone line. If you need a telephone call, or information in another format such as large print, an accessible PDF or plain-text email, tell us and we will arrange it as a reasonable adjustment.
10.3 It will never be harder to complain, disconnect a bank account, withdraw consent, export your data or close your Account than it was to sign up or connect an account. We do not use repeated retention offers, forced phone calls or hidden cancellation routes.
10.4 Emails we send from noreply@notify.earnly.co.uk are not monitored. Every one of them tells you how to contact us.
10.5 If you close your Account or your Agreement ends, you have a 30-day cooling-off period in which you can sign in, export your data and, if you closed your Account yourself, reactivate it, as set out in the "Consequences of termination and data export" clause of the Terms and Conditions.
11. If you need extra help
11.1 Anyone can find themselves in vulnerable circumstances, for example because of ill health, a bereavement, a change in income, a tax bill they cannot pay, or difficulty using digital services. We follow the FCA's guidance on the fair treatment of vulnerable customers.
11.2 If you tell us that you need extra help, we will:
11.2.1 make reasonable adjustments, including extra time, a different format or a telephone call;
11.2.2 deal with someone you have authorised in writing to act for you, such as a family member, an adviser or an attorney;
11.2.3 record only the support you need (for example "prefers telephone contact"), not the reason for it, unless you give your explicit consent to us recording more. You can withdraw that consent at any time;
11.2.4 never use what you tell us about your circumstances to sell you anything; and
11.2.5 point you to free, independent help where it would be useful.
11.3 Free, independent help is available from:
11.3.1 MoneyHelper: moneyhelper.org.uk, 0800 138 7777, for free, impartial money guidance;
11.3.2 StepChange Debt Charity: stepchange.org, 0800 138 1111, for free debt advice;
11.3.3 National Debtline: nationaldebtline.org, 0808 808 4000, for free debt advice, including for the self-employed;
11.3.4 HMRC's extra support service (gov.uk/get-help-hmrc-extra-support) and HMRC's guidance if you are having difficulty paying tax (gov.uk/difficulties-paying-hmrc), including Time to Pay arrangements; and
11.3.5 Samaritans: samaritans.org, 116 123, free, 24 hours a day, if you are struggling to cope. If there is an immediate risk to life, call 999.
11.4 We design the Platform to meet the Web Content Accessibility Guidelines (WCAG) 2.2 at level AA. If you have difficulty using any part of the Platform, please tell us at support@earnly.co.uk.
12. If something goes wrong
12.1 If you are unhappy, please tell us. You can complain by email to complaints@earnly.co.uk, through the online form at https://earnly.co.uk/complaints, in the app through Settings → Help, or by post to Earnly Limited, 41 New Cross Street, Swinton, Manchester, England, M27 4TU. Complaining is free and will never affect how we treat you.
12.2 The Complaints Procedure (https://earnly.co.uk/legal/complaints-policy) forms part of the Agreement and sets out the timescales we commit to. In summary:
12.2.1 we acknowledge every complaint within 2 Business Days;
12.2.2 complaints about the account information service are referred to the Provider within 1 Business Day, and you receive a final response within 15 Business Days (or, in exceptional circumstances, a holding reply within 15 Business Days and a final response within 35 Business Days). Finexer Ltd is responsible for handling these complaints and issuing the final response;
12.2.3 data protection complaints are acknowledged within 2 Business Days (and in any event within 30 days), and we tell you the outcome within one month, or no later than three months for complex complaints; and
12.2.4 other complaints receive a final response within 8 weeks, and we aim to respond within 20 Business Days.
12.3 If your complaint is about the account information service and you are a Consumer, a micro-enterprise, a small business, a small charity or a trustee of a small trust, you may be able to refer it to the Financial Ombudsman Service free of charge, within 6 months of the final response or if you have not received a final response in time (financial-ombudsman.org.uk, 0800 023 4567).
12.4 If your complaint is about how we use your personal data, you can also complain to the Information Commission (ICO) at ico.org.uk or on 0303 123 1113.
12.5 Earnly does not use an alternative dispute resolution scheme for other complaints. If we cannot resolve those, you may go to the courts as set out in the "Governing law and jurisdiction" clause of the Terms and Conditions.
12.6 Where we have got something wrong, we will put it right. We will never make putting things right conditional on you giving up your right to go to the Financial Ombudsman Service or the ICO.
13. How we check we are getting it right
13.1 Every quarter, our Director reviews information about how users are being treated, including support response times, complaints, how quickly disconnections and Account closures are completed, consent reconfirmation rates, how often automatically reviewed categories are later changed, and outcomes for users who needed extra help. He also reviews a sample of real support, complaint and onboarding interactions to check that people received good outcomes.
13.2 Once a year, we carry out a written assessment of whether users are receiving good outcomes and share the parts relevant to the account information service with the Provider, so that it can take them into account in its own Consumer Duty reporting.
13.3 Where we find that users are not receiving good outcomes, we fix the cause, tell the people affected and put things right where appropriate.
13.4 Accountability for fair treatment at Earnly sits with Adam Marsh, Director. We do not operate sales, retention or performance incentive schemes that could reward poor outcomes.
14. Changes to this statement
14.1 We review this statement at least once a year and whenever the Platform, our arrangement with the Provider or the law changes materially. The latest version is always available at https://earnly.co.uk/legal/treating-customers-fairly. Changes to the commitments in the incorporated documents are made under the "Changes to the Agreement" clause of the Terms and Conditions.
15. Contact
15.1 For questions about this statement, contact support@earnly.co.uk or write to Earnly Limited, 41 New Cross Street, Swinton, Manchester, England, M27 4TU.