Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Consumer Duty Demands Proof Of Understanding
Mar 16, 2026 | NCFA Market Insight | Consumer Duty And Digital Finance
Data Source: UK Financial Conduct Authority Financial Lives Survey
Customer Outcomes And Consumer Understanding Framework
On Mar 13, 2026, the UK Financial Conduct Authority published good practice and areas for improvement on consumer understanding, which is critical under Consumer Duty. It's important because the FCA wants firms to show that customers actually understand products, risks, costs, eligibility, and support at the point of decision. This moves the debate past disclosure.
Why The FCA Pushes Harder
The FCA has real evidence about consumer weakness. Its 2024, a UK Financial Lives survey found that 12% of adults, about 6.3 million people, had limited understanding of the products they held.
Another 19%, about 10.3 million, had low confidence with everyday numeracy (34% poor or low financial numeracy). Three in 10 said their preferred communication channel had been withdrawn, causing difficulty for most of them.
See: FCA Stablecoin Sprint Puts Payment Models Under Review
The FCA also cites research showing that 1 in 7 adults have literacy skills at or below those expected of a 9 to 11 year old.
The study also notes that 22% of adults lacked confidence managing money and 36% had low knowledge about financial matters.
Those numbers explain the policy intent. If firms keep pushing more financial decisions into online self serve journeys, regulators want evidence that speed doesn't come at the expense of understanding.
What The FCA Reviewed
The FCA says it used a wide evidence base, including supervisory findings, form data, behavioural research, and engagement with industry bodies, charities, and consumer groups.
It also ran a September 2025 survey of 38 firms across insurance, retail banking, payments, consumer finance, and Contract for Difference providers.
The review focused on five areas: (1) management information and testing, (2) innovation and communication design, (3) vulnerability and accessibility, (4) financial promotions, and (5) governance and oversight.
What Strong Firms Already Do
- They use multiple evidence sources such as call listening, complaints, chat transcripts, website analytics, drop off data, and surveys to identify where customers struggle
- They test communications before and after launch through short surveys, comprehension checks, A B testing, callbacks, and outcome comparisons
- They improve design through plain language, summaries, visual hierarchy, layered information, calculators, walkthroughs, videos, and prompts that help customers act with clarity
- They design and test for vulnerability, accessibility, lower digital confidence, lower capability, sensory impairments, and language needs
- They treat promotions as part of customer understanding, with balanced presentation of risks, limits, benefits, and eligibility
- They assign senior ownership, review management information regularly, track actions, and connect insight back into product and communication changes
3 practical examples
1. One firm used website analytics to find where customers got stuck during a sales process, tested improvements, reduced the number of clicks needed to complete the task, and cut helpline calls.
See: FCA Review of Deferred Payment Credit Rules (BNPL)
2. Another smaller firm tested a renewal letter with customers including two with sight impairments, then introduced large print, a 100 word summary, and clearer next steps. Follow up calls and a micro survey then showed better understanding of excesses and cancellations, with fewer complaints about unclear letters.
3. In another example, a firm set an internal target of at least 80% correct recall of key points when testing communications with customers in vulnerable circumstances and repeated drafting until it hit that threshold.
What Still Fails at Some Firms
- Claim they test communications but provide weak, one off, or poorly documented evidence
- Collect data such as drop off rates or chat logs but cannot show how that evidence informs decisions
- Rely on sales data or the absence of complaints as proof of understanding, which the FCA says is not reliable assurance
- Make cosmetic changes such as shorter wording, icons, or colour adjustments without fixing sequencing, prominence, or clarity of key points
- Do little or no testing with people who have accessibility needs, lower capability, language needs, or lower digital confidence
- Change communications and never measure whether the change actually worked
- Some governance structures still lack clear accountability, customer segmentation, and strong feedback loops from monitoring into action
The FCA is not just asking for better UX or a cleaner narrative. It is asking for an integrated control system that links insight, design, testing, vulnerability, promotions, and governance.
Why Canadian Firms And Policymakers Should Pay Attention
The FCA says the publication may help policymakers and other stakeholders improve customer understanding across financial services. That makes it relevant in Canada on two levels.
See: CSA and CIRO Set Clear Rules for Finfluencers
For fintechs and financial institutions, it offers a practical operating playbook for testing, accessibility, promotions, and governance. For policymakers and regulators, it shows what a more detailed supervisory model looks like when a market evolves from broad conduct guidance to clearer expectations on proof, monitoring, and accountability.
NCFA has already highlighted the demand side of this issue in its analysis of FCA Financial Lives gaps. This new FCA paper adds the supply side. It shows how firms are expected to respond.
Closing Thought
The takeaways travel well beyond the UK. Firms should approach it as an operating model. Policymakers should study it as a regulatory benchmark. Consumer Duty is pushing the market from disclosure to proof, and that's raising the standard for digital finance. If the market wants better outcomes, stronger trust, and fewer harmful misunderstandings, it will need more than disclosure rules alone. It will need evidence that customers actually understand what they are being shown and asked to do.
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