The Financial Conduct Authority has published findings from a review of how firms are delivering the Consumer Duty’s consumer understanding outcome, setting out expectations and illustrative examples of good and poor practice across customer communications, journeys and financial promotions. The FCA emphasises the report does not create new regulatory requirements, but is intended to help firms assess whether their approaches meet existing obligations. The FCA expects firms to run a coherent end-to-end approach spanning insight gathering (including complaints, call listening, chat transcripts, web analytics and customer “drop-off” data), proportionate testing with real customers before and after changes, clear and accessible design using plain language and layered information, and tools such as calculators and walkthroughs. It also points to stronger practices on identifying and supporting customers with characteristics of vulnerability, ensuring promotions are balanced with risks as prominent as benefits, and assigning clear ownership with governance and management information that drives action. Areas for improvement included superficial or undocumented testing, unclear use of management information and reliance on sales data or the absence of complaints as evidence of understanding, insufficient testing with customers who have accessibility needs or lower capability, cosmetic communication changes, overlong documents with limited signposting, unbalanced promotions, and weak accountability and feedback loops. The evidence base included supervisory work and research such as the FCA’s 2024 Financial Lives Survey and a September 2025 survey of 38 firms across insurance, retail banking, payments, consumer finance and contract for difference providers.

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