Trust is the bedrock of banks’ relationships with their customers.
It shapes confidence in financial decisions, underpins long-term relationships, and ultimately determines whether customers believe their bank is acting in their best interest. In today’s regulatory and commercial environment, trust is increasingly influenced by how fairly customers are priced and how transparently they are billed.
Regulators such as the UK Financial Conduct Authority (FCA), through Consumer Duty, have moved the industry away from narrow interpretations of “reasonable” pricing toward broader expectations of fair value and balanced customer outcomes. Similar focus is emerging from the European Banking Authority (EBA) through PSD2 and PSD3 in the EU, and from the Monetary Authority of Singapore (MAS).
This shift recognizes that fairness is not assessed at a single point in time, but across the full pricing lifecycle—from how prices are set, to how they are applied, and how they are reviewed over time. This is especially common in commercial and corporate banking.
This shift also recognizes that fairness is not simply about price levels, but about whether there is a balanced exchange of value. For providers, this is the price paid, and for consumers, it’s the benefits they receive over time.
Fair pricing as a balanced exchange of value
Fair pricing is often misunderstood as a question of whether prices fall within acceptable market ranges. Regulatory guidance increasingly challenges this view. Under the Consumer Duty, firms are expected to demonstrate that pricing delivers fair value through a balanced exchange of value, supported by evidence, governance, and customer understanding.
A balanced exchange of value is achieved when:
- Customers understand the services they are paying for and the drivers of price.
- Pricing outcomes are consistent, explainable, and aligned to delivered benefits.
- Charges reflect service usage, complexity, and customer needs.
- Pricing discretion is applied fairly and governed appropriately.
Critically, this balance must be assessed across three interconnected activities:
Price setting
Price setting establishes the foundation for fair value. It requires clear articulation of pricing objectives, target markets, cost and value drivers, and acceptable pricing ranges. Governance at this stage ensures pricing strategies align with customer outcomes and regulatory expectations, not just commercial targets.
Price application
Price application is where fairness is most visible to customers. Controls must ensure prices are applied consistently and within approved parameters, even where relationship-based discretion exists. Transparent billing plays a vital role in making applied prices understandable and explainable.
Price reviews
Fair value is not static. Regular price reviews are essential to assess whether pricing continues to deliver a balanced exchange of value as products, usage, customer behavior, or market conditions change. Reviews provide the feedback loop required by regulators to identify and remediate poor outcomes.
An end-to-end perspective beyond point-in-time pricing
To credibly demonstrate fair value, banks must view pricing and billing end to end, across both product and customer journeys. This requires consideration of:
- End-to-end product and customer perspective: Pricing should be assessed across the full lifecycle of the product and relationship, not in isolation at onboarding or renewal.
- Governance and oversight: Clear accountability, senior management challenge, and documented decision-making are central to regulatory expectations.
- Controls and testing: Preventive and detective controls, supported by testing and assurance, ensure pricing operates as designed and mitigates conduct risk.
- Systems and procedures: Consistent, automated systems and well-defined procedures reduce manual intervention, support transparency, and enable scalable compliance.
In my experience leading a global pricing and billing transformation program at a large international bank, embedding this end-to-end view proved essential. It connected pricing intent, application, and review through consistent systems, robust governance, and auditable controls, providing regulators and customers with confidence in fair value outcomes.
The treasury challenge of visibility, control, and consistency
Treasury organizations play a central role in enabling businesses to manage costs, liquidity, and risk. Yet controlling bank fees remains a persistent challenge due to fragmented billing formats and practices across geographies. There is also regulatory interest in this given accurate tax collection and fraud prevention.
Digital and standardized billing statements support the price application and review stages by providing consistent, granular data that enables treasurers to validate charges, assess value, and challenge discrepancies effectively.
From transparency to trust through consolidated and digital billing
Many treasury management systems and specialized platforms leverage camt.086 (or TWIST) and AFP codes to deliver consolidated global views of fees, transactions, and balances. By centralizing billing data, treasurers can reconcile charges, detect inconsistencies, and validate pricing against contractual terms.
In that same program at a major global bank (which culminated in a successful regulatory submission), this level of transparency was critical. It ensured consistent pricing across regions, strengthened oversight, and gave regulators clear evidence of end-to-end control, customer understanding, and fair value. Importantly, it shifted client conversations away from dispute resolution to value-based engagement.
Banks that prioritize fairness and transparency-led trust continue to invest in pricing and billing solutions, global coverage, and industry collaboration to meet evolving regulatory and customer expectations.
Aligning fair pricing to treasury maturity
Treasuries differ widely in maturity and analytical capability. A balanced approach recognizes these differences:
- Foundational treasuries establish visibility using AFP codes and basic reporting tools.
- Maturing treasuries adopt straight-through processing and automated reconciliation using camt.086 or TWIST.
- Advanced treasuries leverage global data consolidation, analytics, and BI tools to assess value, support strategic reviews, and prepare for AI-driven insights.
This maturity-based approach ensures Consumer Duty alignment scales pragmatically with organizational capability.
Leveraging industry standards for transparent billing
Industry standards such as TWIST, ISO 20022 camt.086, and AFP Service Codes enable harmonized, structured exchange of billing data. These standards transform billing into transparent, comparable, and auditable information, supporting both customer understanding and fair value assessments.
Fairness and transparency build trust
Under the FCA’s Consumer Duty, fair pricing is no longer defined by whether a charge appears reasonable at a single point in time. It is defined by whether firms can demonstrate, across price setting, application, and review, a balanced exchange of value on a sustainable basis, supported by end-to-end governance, controls, and transparent systems.
By using technology-enabled pricing and billing solutions to embed transparency, standardize billing, and implement lifecycle-based pricing governance, banks can move beyond compliance. They can build lasting trust through fairness, clarity, and confidence in pricing and billing outcomes.
Pricing and billing experts with practical experience and state-of-the-art technology solutions can help banks demonstrate this capability to regulators and build customer trust.
