A UK financial services firm digitising client onboarding needs to solve three problems simultaneously: identity verification that satisfies AML requirements, document execution that holds up legally, and a process that meets the FCA Consumer Duty standard of delivering good outcomes. The technology to do this exists and works. DocuSign or Adobe Sign handles the e-signature layer. Onfido (now part of Entrust) handles identity verification and KYC document checks. Salesforce Financial Services Cloud or an equivalent CRM orchestrates the workflow. The regulatory constraints are specific but manageable — the Electronic Communications Act 2000 and eIDAS make e-signatures legally valid for the vast majority of financial services agreements, and the FCA has not prohibited digital onboarding. The firms that get this wrong are not failing on technology. They are failing on process design, client communication, and the gap between what compliance signed off and what the client actually experiences.
The Regulatory Framework You Actually Need to Understand
Before selecting any technology, a UK financial services firm needs clarity on three regulatory pillars that govern digital onboarding.
The first is the FCA Consumer Duty, which came into force on 31 July 2023 for new and existing products and was extended to closed products on 31 July 2024. The Duty requires firms to deliver good outcomes across four areas: products and services, price and value, consumer understanding, and consumer support. For onboarding, the consumer understanding outcome is the one that bites hardest — your digital process must ensure clients genuinely understand what they are signing up for, not merely that they clicked through a series of screens.
The second is the UK's anti-money laundering framework, primarily the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017), as amended. These require customer due diligence (CDD) before establishing a business relationship. Digital identity verification must meet the same standard as in-person checks — the Joint Money Laundering Steering Group (JMLSG) guidance explicitly permits electronic verification, provided the firm can demonstrate it produces results at least as reliable as document-based checks.
The third is the legal framework for electronic signatures. Under English law, electronic signatures have been valid since the Electronic Communications Act 2000. The Law Commission confirmed in September 2019 that e-signatures can be used to execute documents, including deeds (with witnessing requirements). The eIDAS Regulation, retained in UK law post-Brexit as the UK eIDAS framework, provides the hierarchy: simple electronic signatures, advanced electronic signatures, and qualified electronic signatures. For the vast majority of financial services agreements — client agreements, suitability reports, risk warnings, fund subscriptions — a simple or advanced electronic signature via DocuSign or Adobe Sign is legally sufficient.
The Technology Stack in Detail
The digital onboarding stack for a UK financial services firm breaks into four layers: identity verification, document management, e-signature execution, and workflow orchestration.
Identity verification: Onfido (Entrust). Onfido, acquired by Entrust in April 2024, provides AI-driven document and facial biometric verification. The client photographs their passport or driving licence, takes a selfie, and the system matches the two while checking the document against fraud databases. For UK financial services, Onfido supports the JMLSG's electronic verification standards and can perform PEP (politically exposed person) and sanctions screening. Pricing is custom and volume-based — industry estimates put the median annual spend at around $60,000, though a small IFA firm doing 200 verifications per year will pay considerably less. Alternatives include Jumio, Veriff, and Yoti, all of which serve the UK financial services market.
E-signatures: DocuSign and Adobe Sign. DocuSign offers UK pricing starting at £10 per month for a Personal plan (5 envelopes per month), £25 per user per month for Standard, and £40 per user per month for Business Pro. For a financial services firm processing client agreements, the Standard or Business Pro tier is the practical minimum — you need templates, bulk sending, and audit trails. Adobe Sign is bundled into Adobe Acrobat plans: Acrobat Pro for Teams at roughly £20 per user per month, or Acrobat Studio for Teams at roughly £25 per user per month. Both products produce legally valid electronic signatures under UK law and both generate tamper-evident audit certificates that satisfy FCA record-keeping requirements. The choice between them usually comes down to existing technology relationships — firms already running Adobe Creative Cloud or Microsoft 365 lean towards Adobe Sign; firms running Salesforce lean towards DocuSign, which has a native Salesforce connector.
Workflow orchestration: Salesforce Financial Services Cloud. Salesforce Financial Services Cloud (FSC) sits above the individual tools and orchestrates the full onboarding journey. It provides client record management, task automation, compliance tracking, and a single view of the onboarding pipeline. FSC pricing starts at roughly £120 per user per month for the Sales or Service edition. For a mid-market firm with 10 to 20 advisers plus back-office staff, expect to pay £2,000 to £5,000 per month for the CRM layer alone. Alternatives include Microsoft Dynamics 365 Financial Services, Intelliflo (for wealth management), and Iress (for financial planning). The critical requirement is not which CRM you choose — it is that the onboarding workflow is codified, auditable, and connected to your compliance monitoring.
Designing the Onboarding Workflow
Digital vs Manual Onboarding Timeline
Comparison of average onboarding time in business days for manual paper-based processes versus a digitised workflow across key stages
Source: UK financial services operational benchmarks, 2024-2026
A compliant digital onboarding workflow for a UK financial services firm typically follows seven stages. Each stage has specific regulatory touchpoints.
Stage 1: Initial engagement and triage. The client expresses interest. Your system captures basic contact details and determines the service type requested. Under Consumer Duty, this is where you begin demonstrating that the product or service is appropriate for the client's needs — not after the paperwork is signed.
Stage 2: Identity verification. The client completes KYC checks via Onfido or equivalent. This satisfies the MLR 2017 CDD requirements. The system should capture the verification result, the confidence score, and any flags for enhanced due diligence. Firms handling clients who are PEPs or from high-risk jurisdictions must apply enhanced due diligence before proceeding.
Stage 3: Fact find and suitability assessment. The adviser completes the fact find digitally. For regulated advice, this produces the information needed for the suitability report under COBS 9. The fact find should be completed in a format that the client can review and correct — Consumer Duty requires that clients understand the basis on which advice is given.
Stage 4: Documentation and disclosure. The firm generates the client agreement, terms of business, fee disclosure, risk warnings, and any product-specific documentation. Consumer Duty's consumer understanding outcome requires that these documents are clear, not misleading, and appropriate for the target market. A 40-page terms document sent as a single PDF with a "sign here" tag does not meet this standard.
Stage 5: E-signature execution. Documents are sent via DocuSign or Adobe Sign. The client reviews and signs electronically. The audit trail records the time, IP address, authentication method, and signing sequence. For documents that require witnessing (such as deeds of trust), the e-signature platform must support witness workflows — both DocuSign and Adobe Sign offer this.
Stage 6: Compliance review and approval. The compliance team reviews the completed onboarding pack before the business relationship is activated. In a well-designed digital workflow, this review happens within the CRM, with automated checks flagging incomplete items, missing signatures, or failed identity verification.
Stage 7: Client confirmation and access. The client receives confirmation that onboarding is complete, along with copies of all signed documents, login credentials for any client portal, and clear information about how to contact the firm. Consumer Duty's consumer support outcome requires that clients can reach you through reasonable channels — a digital-only firm must still provide human support when clients need it.
Where Digital Onboarding Goes Wrong in Practice
The technology works. The failures are almost always in the design and communication layers.
Failure one: treating e-signatures as the whole solution. Firms buy DocuSign, attach it to their existing PDF documents, and call the process digital. This changes the signature method but does nothing for the onboarding experience. The client still receives a 30-page document by email with no context, no plain-language summary, and no indication of which sections are relevant to their situation. Under Consumer Duty, this is a consumer understanding failure waiting to happen.
Failure two: identity verification disconnected from the workflow. The KYC check runs through one system. The client agreement runs through another. The CRM records the relationship but does not link the two. When the compliance team asks whether CDD was completed before the agreement was executed, nobody can answer without checking three systems. The fix is straightforward: the identity verification result must be recorded in the CRM and linked to the client record before document execution is triggered.
Failure three: no fallback for clients who cannot complete the digital journey. Not every client can photograph their passport with a smartphone. Not every client is comfortable signing documents on a screen. Consumer Duty's consumer support outcome requires firms to provide alternative routes for clients who face barriers. Your digital onboarding process needs a defined fallback — typically a video call with an adviser who can guide the client through the process or, where necessary, accept paper documents.
Failure four: compliance sign-off on the technology but not the journey. The compliance team reviews the individual tools — DocuSign meets the e-signature standard, Onfido meets the KYC standard, Salesforce meets the record-keeping standard. But nobody maps the full client journey from first contact to activated account and checks whether the experience, as a whole, delivers the Consumer Duty outcomes. This is where the FCA's forthcoming digital journeys assessment will focus — and firms that have not done this work themselves will be unprepared.
Fifth, firms underestimate the training requirement. Advisers who have spent 15 years filling in paper application forms do not switch to a digital workflow overnight. Budget for a minimum of two half-day training sessions per adviser, with follow-up support available for the first three months. The firms that skimp on training invariably see advisers reverting to paper processes within weeks, which creates a worse outcome than not digitising at all — you end up paying for the technology while still running the manual process alongside it.
Sixth, there is the client communication gap. Existing clients expect the onboarding process they experienced when they first joined. If you switch to a digital journey without explaining the change clearly, you generate complaints and lost trust. Send a clear letter — not an email buried in a newsletter — explaining what is changing, why, and what the client needs to do. Include a telephone number for clients who want to discuss the change with a person. The Consumer Duty's Outcome 1 (products and services) requires that the shift to digital does not create a worse outcome for any client segment.
The FCA's Digital Journeys Assessment
The FCA announced that it would publish findings from its assessment of firms' digital journeys in H1 2025. This assessment examines how firms design, test, and monitor their digital customer journeys, with particular attention to whether the journeys deliver good outcomes under the Consumer Duty.
For firms digitising onboarding now, this means building monitoring into the process from day one. Track completion rates at each stage. Measure the time clients spend on key disclosure documents. Record where clients drop out or request human support. This data serves two purposes: it demonstrates to the FCA that you are monitoring outcomes, and it tells you where your onboarding process needs improving.
The firms that will perform well in the FCA's assessment are the ones that treat digital onboarding as a product in its own right — something that is designed, tested with real clients, monitored continuously, and improved iteratively. The firms that will perform badly are the ones that bought a technology stack and assumed the job was done.
What This Costs in Practice
Annual Technology Cost Breakdown
Estimated annual costs for a UK mid-market financial services firm digitising client onboarding with 15 advisers and 500 clients per year
Source: Vendor pricing pages and market rate estimates, February 2026
For a mid-market UK financial services firm with 15 advisers onboarding 500 clients per year, a realistic technology budget looks like this. Salesforce Financial Services Cloud at £120 per user per month for 20 users comes to roughly £2,400 per month. DocuSign Business Pro at £40 per user per month for 15 users comes to £600 per month. Onfido identity verification at an estimated £5 to £15 per check for 500 checks per year comes to roughly £200 to £625 per month averaged. Total technology cost: roughly £3,200 to £3,600 per month, or £38,000 to £43,000 per year.
On top of the technology, budget for configuration and setup. A Salesforce partner to configure FSC for your onboarding workflow will cost £15,000 to £40,000 depending on complexity. DocuSign template setup and training is typically £2,000 to £5,000. Onfido configuration and testing runs £1,000 to £3,000. Total first-year cost including setup: roughly £56,000 to £91,000. Subsequent years: roughly £38,000 to £43,000.
This is not cheap. But compare it to the cost of the current manual process: adviser time spent on paper forms, compliance review of physical documents, storage costs, and the risk of a Consumer Duty finding from the FCA. For firms already exploring AI governance for their mid-market operations, digital onboarding fits within the same modernisation programme. The payback period depends on current onboarding volume and error rates, but firms processing more than 300 new clients per year typically see a positive return within 18 months.
Migrating Existing Client Data Without Breaking Anything
The question every operations director asks eventually: what happens to the 3,000 clients already on the books? Migrating historical client data into a new digital onboarding platform is where projects stall, and it deserves its own planning workstream.
Start by auditing your existing client records against current regulatory requirements. Firms often discover that records opened before 2017 do not meet current MLR standards for identity verification evidence. That creates a decision: do you back-fill those records during migration, or flag them for periodic review under your existing risk framework? The answer depends on your compliance risk appetite, but the FCA expects firms to be able to demonstrate that they have considered the question.
Data mapping is the technical bottleneck. Legacy systems — whether that is a bespoke Access database, a folder of PDFs on a shared drive, or an ageing installation of Intelliflo — rarely export data in formats that map cleanly to modern CRM field structures. Budget 40 to 60 hours of data cleansing for every 1,000 client records, and do not assume that a CSV export from your old system will be accurate. Field truncation, character encoding errors, and inconsistent date formats are the norm, not the exception.
Run the migration in batches. Move 50 records first, verify them manually against source documents, then fix the mapping rules before processing the next 500. Firms that attempt a single bulk migration invariably discover errors weeks later when a client calls about incorrect details on their annual review letter.
