Treating Customers Fairly Policy

Version 1.0 | Published: 31 May 2026 | Last reviewed: 31 May 2026

This policy sets out how Otis Tax (This is Otis Ltd) treats customers fairly in line with the Financial Conduct Authority's Principle 6. It covers our commitments across all six TCF consumer outcomes.

Our Commitment

Otis Tax (This is Otis Ltd) is committed to treating all customers fairly in line with the Financial Conduct Authority's (FCA) Principle 6, which requires firms to pay due regard to the interests of customers and treat them fairly.

Our users are predominantly sole traders and freelancers navigating Making Tax Digital for Income Tax, often without professional representation. Fair treatment is not simply a compliance obligation for us. It is central to why the product exists.

The Six TCF Outcomes

The FCA has defined six consumer outcomes that firms should work toward. Below we set out how Otis Tax addresses each one.

Outcome 1: Fair treatment is central to our culture

Otis Tax is a founder-led business. The Directors holds direct responsibility for customer experience, product decisions, and complaint handling. There is no separation between leadership and customer outcomes. Every product decision is evaluated against whether it genuinely serves the needs of an unrepresented sole trader, and feedback from users is actively used to shape the product roadmap.

Outcome 2: Products are designed to meet the needs of identified customer groups

Otis Tax is built specifically for sole traders, landlords and freelancers who are mandated to comply with Making Tax Digital for Income Tax and who do not have an accountant managing their affairs. The product is deliberately narrow in scope: it does one thing, MTD compliance, and does it as simply as possible. Pricing, features, and user experience are all designed with this specific group in mind.

  • The spreadsheet upload pathway is designed for users who already manage their finances in Excel or CSV format, removing the need to adopt new tools
  • Open banking integration, currently in development, will serve users who want an even simpler pathway with no manual input required
  • Pricing is annual and submission-based, reflecting how our users think about tax: at defined points in the year, not as an ongoing monthly overhead

Outcome 3: Customers receive clear information before, during, and after the point of sale

We are committed to clear, plain-English communication at every stage of the user journey:

  • Pricing is transparent and displayed clearly before any payment is taken
  • The MTD submission process is explained in plain language throughout the platform
  • Users receive confirmation of every submission made to HMRC
  • Deadline reminders are sent ahead of each quarterly submission window
  • Users can see a live estimate of their tax liability at any point

Outcome 4: Where advice is given, it is suitable

Otis Tax is a software product, not an advisory service, and we do not provide regulated financial or tax advice. We are clear with users about this distinction. The product assists with the mechanical process of MTD compliance: gathering, formatting, and submitting data to HMRC. Where users have questions that go beyond the scope of the product, we signpost them to appropriate resources including HMRC guidance and professional tax advisers.

Outcome 5: Products perform as expected and service is of an acceptable standard

We are committed to delivering a reliable, accurate service:

  • All submissions use HMRC's official MTD API, ensuring data reaches HMRC in the correct format
  • HMRC Assist is integrated into the platform, flagging potential discrepancies before a return is finalised
  • We use Sentry for real-time error monitoring, with root cause analysis conducted following any significant incident
  • During peak submission periods, pre-deadline readiness checks confirm the platform is stable when users need it most
  • In the event of a service outage coinciding with an MTD deadline, we liaise directly with our HMRC account manager to ensure users are not penalised

Outcome 6: Customers do not face unreasonable barriers after the point of sale

We are committed to making it straightforward for users to get support, raise concerns, or leave the service:

  • Our Complaints Policy sets out a clear process for raising concerns, with a response commitment of 3 business days and resolution within 15 business days
  • Users can request deletion of their account and data at any time
  • There are no long-term contracts or cancellation penalties
  • Users can contact the Directors directly and will receive a personal, prompt response

Vulnerable Customers

We recognise that some users may be in vulnerable circumstances, including those unfamiliar with digital tools, those under financial stress, or those who find the tax system particularly difficult to navigate. Our product is designed with simplicity as a core principle, which benefits all users but particularly those who might otherwise struggle with more complex software.

Where a user contacts us and it is apparent they need additional support, we will respond with patience and care, and where appropriate signpost them to further help including HMRC's own support services.

Monitoring and Review

The Directors is responsible for monitoring TCF outcomes on an ongoing basis. This includes reviewing complaints and user feedback, monitoring submission success rates, and assessing whether the product continues to serve the needs of our target users as the MTD regime evolves.

This policy will be reviewed annually or following any significant change to our product, customer base, or regulatory environment.

Contact

If you have any questions about this policy or how we treat customers, please contact us:

Postal Address: 124 City Road, London, EC1V 2NX

This policy was prepared on 31 May 2026 and will be reviewed annually. Otis Tax (This is Otis Ltd) is registered in England and Wales.