UK financial regulation & the FCA

1. Summary position

Myri is a personal budgeting and financial-education app for iPhone. It runs entirely on the user's own device, stores all data locally, and helps people understand their own money using figures they enter or import themselves.

Myri is designed so that it does not carry on any activity that is regulated by the FCA under the Financial Services and Markets Act 2000 (FSMA). It does not give regulated financial advice, does not handle anyone's money, and does not sell, arrange, or recommend any financial product. On that basis, we consider that Myri does not require FCA authorisation. We set out the reasoning below so it can be checked point by point.

2. What Myri is, and what it is not

Myri is:

• A calculator and organiser for your own budget, drawing on income, transactions and goals you enter or import from your own bank's CSV export
• A source of generic, educational information: for example, how UK tax bands work, or how long a debt takes to clear at a given payment
• A piece of software you buy once and run privately on your phone

Myri is not:

• A financial adviser. It never tells you to buy, sell, or hold a specific investment, pension, mortgage, insurance or other regulated product.
• A bank, e-money or payment service. It never holds, moves, or has access to your money.
• A broker, lender, or credit firm. It does not arrange, provide, or introduce you to any credit or financial product.
• A debt-advice or debt-management service. It does not negotiate with creditors or manage repayments on your behalf.

3. Myri does not carry on FCA-regulated activities

The activities that require FCA authorisation are set out in the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (the "RAO"). Myri is built so that none of them apply. Specifically, Myri does not:

• Advise on investments: it gives no personal recommendation to buy or sell a particular investment or product (RAO art. 53)
• Arrange or deal in investments: it makes no arrangements for anyone to buy, sell or subscribe for investments (RAO arts. 21, 25)
• Manage investments: it manages no assets belonging to anyone (RAO art. 37)
• Hold or control client money or assets: it never receives, holds, or safeguards funds (CASS does not apply)
• Provide payment services or e-money: it transmits no payments and issues no e-money (PSRs 2017 / EMRs 2011 do not apply)
• Carry on consumer-credit activities: no lending, credit broking, debt counselling, debt adjusting, or debt collecting as a business (RAO arts. 60B onwards)
• Accept deposits, or arrange/advise on insurance, mortgages, or pensions

Because Myri performs none of these activities, we consider it falls outside the regulatory perimeter and does not need to be authorised or registered as a regulated firm.

4. Information and tools, not regulated advice

The FCA's Perimeter Guidance (PERG 8) draws a clear line between generic information and a personal recommendation. Myri stays firmly on the information side:

• Every number Myri shows is a calculation based on data you entered: it is arithmetic about your own situation, not an opinion on the merits of a regulated product.
• Myri never says "you should buy / sell / switch to" any specific named financial product.
• Where a decision could benefit from regulated advice, Myri signposts you to an FCA-authorised adviser and to free, impartial guidance (see section 8).

This mirrors the way budgeting spreadsheets, tax calculators, and personal-finance books operate: they inform; they do not advise.

5. Debt tools, not debt counselling

Debt counselling and debt adjusting are regulated activities, so we are especially careful here. Myri's debt features are self-service calculators: you enter your own debts, and Myri shows the maths of different repayment orders (such as avalanche or snowball), total interest, and an estimated debt-free date.

• Myri does not recommend a specific course of action, contact your creditors, negotiate, or manage payments.
• Myri does not hold itself out as a debt-advice service.
• For anyone who needs help with problem debt, Myri points to free, regulated debt advice: StepChange, National Debtline, Citizens Advice, and MoneyHelper.

6. Financial promotions

Section 21 of FSMA restricts inviting people to engage in regulated financial activity. Myri's marketing promotes a software application, not a regulated financial product or service, so the restriction is not engaged by what we advertise. Regardless, we hold our marketing to the same standard the FCA expects: communications that are fair, clear, and not misleading. Myri makes no promises about investment returns, makes no "get rich" claims, and describes pricing transparently.

7. Consumer protection & treating users fairly

The FCA's Consumer Duty applies to authorised firms. As an unregulated tool we are not bound by it, but we have voluntarily adopted its spirit because it is simply how a fair product should behave:

• Fair value & price transparency: one clear one-time price, shown up front, with no subscription and no "premium" paywall on your own data.
• No dark patterns: no pressure to share data, no hidden auto-renewals, no manipulative nudges.
• Clarity & honesty: projections use high-precision arithmetic and are labelled as estimates based on your inputs and assumptions, not guarantees.
• Accessibility & support: a published support channel and plain-English documentation.

8. Signposting to regulated help

Myri is a starting point for understanding your money, not a substitute for regulated advice. Throughout the app and this site we direct people to:

• MoneyHelper (the government's free, impartial money-guidance service): moneyhelper.org.uk
• The FCA Register, to check that any adviser or firm is authorised: register.fca.org.uk
• Free debt advice: StepChange, National Debtline, and Citizens Advice
• FCA-authorised financial advisers, for advice specific to your circumstances

9. Your data & UK GDPR

Data protection is overseen by the Information Commissioner's Office (ICO) rather than the FCA, but it matters to consumer trust, so we mention it here. Myri keeps all personal and financial data on your device only: there are no Myri servers, accounts, analytics, or trackers, so there is no central store of customer data to misuse or lose. Full detail is in our Privacy Policy.

10. Anti-money laundering

The Money Laundering Regulations 2017 apply to businesses that handle or transmit funds. Myri never receives, holds, or moves money (your one-time purchase is processed by Apple through the App Store), so Myri is not a relevant person under those regulations.

11. Honesty about the limits of this page

We want to be straight about three things:

• This is our own assessment. It reflects how Myri is designed and operated today. If any feature changes in a way that touches a regulated activity, this position would need to be re-examined.
• The FCA does not pre-approve apps. The FCA does not generally issue "you will not be fined" confirmations for unregulated products. Where genuine uncertainty exists about the perimeter, the right routes are a qualified adviser, the FCA's published Perimeter Guidance (PERG), or the FCA's innovation services.
• We welcome scrutiny. If the FCA or a qualified professional identifies anything on this page that should be corrected, we will correct it promptly.

References on this page to FSMA, the Regulated Activities Order, PERG, the Consumer Duty, the Payment Services Regulations, UK GDPR and the Money Laundering Regulations are provided for general context only and are paraphrased in plain English. They are not a substitute for reading the legislation itself or obtaining professional advice.