Veracent Intelligence — Evidence Criteria
Version 1.3 · Effective 14 September 2026 · Companion to the Research Methodology
This page lists every criterion Veracent examines, what evidence is required to mark it Verified, and how quickly that evidence goes stale. Read alongside the methodology, it allows any reader to reconstruct how a report was produced.
How to read this page. Each criterion has an ID, a question it answers, a data class (which sets its decay rate — see methodology §6.2), the minimum evidence required for a Verified state, and the conditions under which it is marked Not Applicable and removed from scoring.
Criteria marked [Core] must be resolved for a report to be published at all. See §7 below.
1. Regulatory Standing — REG
Applicable to all entities. Where an entity operates under multiple regulators, each jurisdiction is assessed separately and reported separately.
| ID | Question | Class | Verified requires | N/A when |
|---|---|---|---|---|
| REG-01 [Core] | Is the entity authorised, and by which regulator? | Slow | Direct match on a statutory register (FCA Register, or equivalent home regulator) to the specific legal entity, by firm reference number | Never — unauthorised status is itself a finding |
| REG-02 [Core] | What is the entity's current authorisation status? | Slow | Register status field (Authorised / EMI / AR / Cancelled / Restricted) as published | Never |
| REG-03 | Which regulated permissions does the entity hold? | Slow | Permissions schedule from the register | Entity not authorised |
| REG-04 | Is the entity an Appointed Representative, and of whom? | Slow | Register principal-firm relationship record | Entity is directly authorised |
| REG-05 | What trading names are registered to this entity? | Slow | Register trading-name record | No trading names registered |
| REG-06 | Do the registered office and the regulator's recorded place of business agree? | Slow-changing | The company registry's recorded registered office and the regulator's recorded principal place of business, compared. Neither record is customer-facing: what a firm shows its customers is REG-10. | — |
| REG-07 | Are there requirements, restrictions or waivers on the permissions? | Slow | Register requirements/waivers section | None recorded |
| REG-08 | What cross-border or passporting permissions does the register record? | Slow-changing | The register's passporting or cross-border permission records. These state what the entity is permitted to do, not where it markets. Since the UK left the EEA a UK firm can passport only to Gibraltar, so this field reads alike for firms with and without overseas business. | The register records no cross-border permissions and the entity operates in one jurisdiction |
| REG-09 | Does the customer-facing brand map to the authorised entity? | Structural | Documented link between brand and FRN in the entity's own regulatory disclosures | Brand and entity name identical |
| REG-10 | Is regulatory status disclosed clearly to customers at point of sale? | Fast | Regulatory disclosure located on the entity's own site or client agreement | — |
2. Client Asset Protection — CAP
Applicable where the entity holds client money or client assets. Marked N/A in full for entities that do not, which is itself stated in the report.
| ID | Question | Class | Verified requires | N/A when |
|---|---|---|---|---|
| CAP-01 [Core] | Does the entity hold client money or assets? | Slow | Regulatory permissions, or the client agreement | — |
| CAP-02 [Core] | Who holds client money, and under which regime is it held? | Slow | A binding document stating how customer money is held and by whom. Where the arrangement differs by product or by stage — held as banker before settlement and as client money after, or under scheme rules in one account and client money rules in another — record each. | The entity holds no client money and the register records no permission to do so |
| CAP-03 | Which institution(s) hold segregated client money? | Slow | Named banks in a filed or binding document | Not disclosed anywhere; entity holds no client money |
| CAP-04 | Which entity acts as custodian for client securities? | Slow | Client agreement or filed accounts naming the custodian | No securities custody |
| CAP-05 | Which entity acts as custodian of client assets, and is it a separate legal entity from the operator? | Structural | The client agreement or a filed document identifying the custodian. Where custody is outsourced, registry confirmation that the named custodian is a distinct registered company. Where the operator states it custodies client assets itself, that statement is the answer. | The entity holds no client assets |
| CAP-06 | Which compensation scheme applies to the entity, or does none apply? | Structural | The scheme's own register matched to the entity, or the entity's binding statement of which scheme covers it. Where no scheme applies, the entity's own disclosure to that effect is the answer. | — |
| CAP-07 | What is the per-customer compensation limit? | Slow | Scheme's published limit for the relevant activity | No scheme applies |
| CAP-08 | Do compensation limits differ by product held? | Structural | Scheme rules cross-referenced against the entity's products | No compensation scheme covers the entity, so there are no limits to differ |
| CAP-09 | Is there evidence of independent assurance over client asset arrangements? | Slow | Auditor's client assets report, or equivalent published assurance | — |
| CAP-10 | What does the entity disclose about client assets if it fails? | Structural | A binding document addressing the position of client assets on the entity's failure. A statement that no compensation or deposit protection applies is an answer to this question, not an absence of one. | — |
| CAP-11 | Are client assets subject to lending, rehypothecation or re-use? | Slow | Client agreement clause on stock lending / re-use | — |
3. Cost Transparency — COST
Assessed per product and per account type. Fee criteria are fast-decaying and are suppressed rather than shown stale.
| ID | Question | Class | Verified requires | N/A when |
|---|---|---|---|---|
| COST-01 [Core] | Is a complete fee schedule publicly available? | Fast | A single published document or page covering all charge types | — |
| COST-02 | What commission or dealing charges apply? | Fast | Published fee schedule or client agreement | No dealing activity |
| COST-03 | What is the FX or currency conversion charge? | Fast | Published rate, with the base rate it applies to stated | No multi-currency activity |
| COST-04 | What reference rate does the entity state it uses for currency conversion? | Fast-changing | The entity's own statement of the rate it converts at — a named provider's rate, a mid-market point, a panel quotation, or its own internal rate — together with any margin added to it. Record what the document says the rate is; do not compare it to a benchmark the document does not name. | — |
| COST-05 | What spread or implicit cost applies, and is it disclosed? | Fast | Published spread data or explicit disclosure of spread as a cost | Fixed-fee product |
| COST-06 | Are there account, platform or custody fees? | Fast | Fee schedule | — |
| COST-07 | Are there inactivity or dormancy charges? | Fast | Fee schedule or client agreement | — |
| COST-08 | What withdrawal, transfer-out or closure charges apply? | Fast | Fee schedule | — |
| COST-09 | Do headline marketing claims (e.g. "commission-free", "zero fees") match the binding fee schedule? | Fast | Direct comparison of marketing page against client agreement | No such claims made |
| COST-10 | Are interest arrangements on cash balances disclosed, including any retained share? | Fast | Published statement of rate paid and rate retained | No cash balances held |
| COST-11 | How much notice is given before charges or terms change? | Slow-changing | A notice period clause in the client agreement. Where charges carry a separate period from the agreement as a whole, record both. | — |
Where COST-09 identifies a mismatch between marketing material and binding terms, the criterion is recorded as Contradicted and both sources are published in full. We do not characterise the mismatch; we show it.
4. Security and Operational Controls — SEC
We assess published controls only. We do not test systems, attempt access, or infer security posture from absence of disclosure.
| ID | Question | Class | Verified requires | N/A when |
|---|---|---|---|---|
| SEC-01 | Is multi-factor authentication offered, and is it mandatory or optional? | Fast | Published security documentation | — |
| SEC-02 | Are recognised security certifications held (e.g. ISO 27001, SOC 2)? | Slow | Certificate or certifying body's register — never the entity's claim alone | — |
| SEC-03 | Is there a published vulnerability disclosure or bug bounty route? | Slow | Published policy page | — |
| SEC-04 | Have security or data incidents been publicly disclosed, and how were they handled? | Slow | Regulator notice, ICO action, or contemporaneous independent reporting | No incidents located |
| SEC-05 | Are operational resilience or continuity arrangements disclosed? | Slow | Filed accounts, regulatory disclosure, or published policy | — |
| SEC-06 | Have material service outages been reported, and were they disclosed by the entity? | Slow | Independent reporting or the entity's own status history | — |
| SEC-07 | Is a data protection registration in place, and with whom? | Slow | ICO register or equivalent | — |
5. Corporate Transparency — CORP
| ID | Question | Class | Verified requires | N/A when |
|---|---|---|---|---|
| CORP-01 [Core] | What is the entity's registered company number and legal form? | Structural | Companies House or equivalent registry | — |
| CORP-02 [Core] | Who are the persons with significant control? | Slow | Companies House PSC register | PSC exemption applies — stated |
| CORP-03 | What is the group structure above this entity? | Slow | Filed group accounts or registry ownership records | No parent |
| CORP-04 | Which jurisdiction is the ultimate parent registered in? | Slow | Registry record of the parent | No parent |
| CORP-05 | Are accounts filed on time and to the required standard? | Slow | Companies House filing history and deadlines | Newly incorporated, no deadline passed |
| CORP-06 | Are the accounts audited, and by whom? | Slow | Auditor's report in the filed accounts | Audit exemption claimed — stated |
| CORP-07 | Is there a going-concern qualification or emphasis of matter? | Slow | Auditor's report | Unaudited |
| CORP-08 | When was the entity incorporated? | Structural | The registry's recorded incorporation date. This records when the legal entity came into existence and does not establish how long it has traded under its current name; CORP-09 records name history. | — |
| CORP-09 | Have there been recent changes of control, name or registered office? | Slow | Companies House filing history | None in the evidence window |
| CORP-10 | Are directors disqualified, or associated with disqualification? | Slow | Companies House disqualified directors register | No matches |
6. Conduct and Track Record — CON
The most legally sensitive dimension. We publish only what a regulator, court or ombudsman has itself published. We do not aggregate allegations, and we do not treat complaint volume as evidence of misconduct.
| ID | Question | Class | Verified requires | N/A when |
|---|---|---|---|---|
| CON-01 [Core] | Are there published regulatory enforcement actions against this entity? | Slow | The regulator's own published final notice or decision — Tier 1 only | None located |
| CON-02 | Are there published enforcement actions against the parent or sister entities? | Slow | Regulator's own publication, entity-matched | No group entities |
| CON-03 | Are there published warnings or unauthorised-firm alerts naming this entity or a clone of it? | Slow | Regulator warning list | None located |
| CON-04 | What complaints data does the entity publish, as required? | Slow | The entity's mandatory complaints return | Not subject to the requirement |
| CON-05 | What complaint volumes does the ombudsman publish about the entity? | Slow-changing | The Financial Ombudsman Service's published half-yearly business complaints data, and where published, the proportion upheld. The Service publishes firm-level figures only above a complaint threshold: a firm absent from a release falls below it, which is not evidence that no complaints were made. Raw volumes are not comparable between firms of different sizes. | The entity is outside the Financial Ombudsman Service's jurisdiction |
| CON-06 | Is there material litigation of public record? | Slow | Court judgment or filed proceedings | None located |
| CON-07 | Have directors been subject to published regulatory action in their individual capacity? | Slow | Regulator's individual register | None located |
Standing rule for this dimension: where no action is found, the criterion reads "No published enforcement action located in the evidence window" — never "clean record", "no wrongdoing", or any phrasing implying we have verified the absence of misconduct. We have verified only the absence of published findings within our sources and window.
7. Publication thresholds
The methodology (§10) commits us to withholding reports below a minimum evidence standard. Those minimums are:
| Requirement | Threshold |
|---|---|
| Core criteria resolved | All criteria marked [Core] must be in a state other than Not Found |
| Entity resolution | The entity must be matched to a specific company number and, where the activity requires authorisation, a firm reference number |
| Overall Evidence Completeness | ≥ 60% across all applicable criteria |
| Official Source Ratio | ≥ 40% of addressed criteria at Tier 1 or Tier 2 |
| Regulatory dimension coverage | ≥ 80% — we do not publish on a firm whose regulatory position we cannot largely establish |
| Unresolved contradictions | No unresolved contradiction on a [Core] criterion |
Where a report falls below these thresholds, we publish nothing rather than publishing a weak report with caveats. A report that fails to meet the threshold is recorded internally so the reader can be told "we examined this firm and could not meet our publication standard" — which is itself honest information, and is stated without characterising the firm.
8. Criteria changes
Criteria are versioned. When a criterion is added, removed or reworded, the change is logged below and affected reports are re-run before their figures are updated. We do not compare figures produced under different criteria versions without saying so.
| Version | Date | Change |
|---|---|---|
| 1.0 | 30 August 2026 | Initial publication. |
| 1.1 | 31 August 2026 | CAP-05 corrected. The criterion asked whether the custodian is a separate legal entity from the operator, but required tier 1 registry evidence alone. A company registry records that companies exist; it cannot record who performs custody, which is stated in the client agreement. The criterion was therefore unanswerable for any firm that custodies its own client assets — a material fact version 1.0 had no way to record. Minimum tier changed from 1 to 2 and the evidence standard rewritten. No other criterion, weighting or threshold changed. All reports published under 1.0 were re-assessed under 1.1. |
| 1.2 | 7 September 2026 | Six criteria corrected, each found by applying them to firms of a kind the earlier wording did not anticipate. CORP-08 no longer conflates incorporation with trading continuity (found on Starling Bank, incorporated as POSSIBLE FS LIMITED). REG-08 asks what cross-border permissions the register records rather than where a firm markets, since post-Brexit a UK firm can passport only to Gibraltar and the field reads alike for firms with no overseas business. CAP-06 accepts the entity's own binding statement of which scheme applies, because no register can establish that none does (found on Wise Payments, an e-money institution outside FSCS). CAP-08 is not applicable where no scheme covers the entity. CAP-10 accepts disclosure that no protection applies as an answer about failure. COST-11 asks about notice of changes to charges or terms, as agreements actually express it. CAP-02 asks who holds client money and under which regime, because firms hold it differently at different stages or in different products (found on Monzo and Hargreaves Lansdown). No weighting, source tier or publication threshold changed. All published reports were re-assessed under 1.2. |
| 1.3 | 14 September 2026 | Three criteria corrected, each already rejected on a published report rather than predicted. REG-06 asks whether the registered office and the regulator's recorded place of business agree, rather than whether either matches an address presented to customers — a question no pair of registers can answer, and one REG-10 already covers. It had been rejected on three reports in a single day. COST-04 asks what reference rate the entity states it uses, rather than naming the interbank rate in the question: four separate claims across four firms asserted a comparison with a benchmark their sources never mentioned, because a benchmark named in a question gets reached for whether the document mentions it or not. CON-05 asks for the complaint volumes the ombudsman publishes openly, rather than an uphold pattern available only from a decisions database closed to automated access. No weighting, source tier or publication threshold changed. All published reports were re-assessed under 1.3. |
On changing criteria. A criterion is amended only where it is logically incapable of being answered correctly — never because a report fell short of it. Publication thresholds are not adjusted to admit a specific report. Where a change is made, every affected report is re-assessed and must pass validation again under the new version, and the reason is recorded above.