Durable medium

Definition

A durable medium is any instrument that lets a client store information addressed personally to them, in a way that is accessible for future reference for as long as the information is relevant, and that allows the unchanged reproduction of that information. The definition comes from the Insurance Distribution Directive and is mirrored in the FCA Handbook glossary for UK firms. Paper is the benchmark; a PDF attached to an email, a secure client portal with downloadable documents or a USB key also qualify. The concept matters because contract terms, the insurance product information document, demands-and-needs statements and other pre-contractual information must be provided on paper or, subject to conditions, on another durable medium. A web page the firm can alter, or a message that can be deleted by the sender, does not meet the test.

What you need to know

For UK and Irish brokers, ICOBS allows information to be provided on a durable medium other than paper where it is appropriate to the business conducted and the client has chosen it. Dutch and Nordic firms apply the same IDD test through their national rules. South Africa does not use the term in the same way, but the FAIS General Code requires that disclosures and records of advice be provided in a form the client can keep, and POPIA requires that personal information in those documents be kept securely and not for longer than needed.

Is WhatsApp a durable medium? Partly. A PDF sent in a conversation is downloadable and can be reproduced unchanged by the client, so that file meets the criteria. The chat thread itself does not: messages can be deleted, disappearing messages exist, and the firm cannot control what the client retains. A careful brokerage sends contractual documents as attachments on WhatsApp and by email, logs the evidence of delivery, and never treats a "yes" in the thread as a signature or as acceptance of terms.

ORIS sends documents from the shared inbox through the WhatsApp Business API, which gives the brokerage the timestamp, the delivered and read receipts, and a complete history attached to the customer record. See our note on a shared WhatsApp inbox and Consumer Duty record-keeping, and the compliance hub for other markets.

Concrete example

A Manchester broker renews a commercial combined policy. The account handler sends the renewal schedule, the IPID and the demands-and-needs statement as PDFs in the client's WhatsApp thread and by email to the director's address. The file note records both deliveries and the date the client chose electronic documents. When the client disputes a wording a year later, the PDFs and the read receipts are retrieved in a minute.