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The FCA review of ‘Digital design in customers online journeys’ signals how firms need to ensure their journeys balance efficiency with delivering good outcomes under the Consumer Duty.
The regulator’s report highlighted that while digital platforms can enhance clarity, accessibility, and support, they also risk nudging customers into poor decisions when badly designed.
The review also signposts how the FCA will use assessments of firms’ digital experiences to check whether they’re meeting the Duty’s key outcomes requirements.
Digital design done well: A foundation for good outcomes
The FCA praised firms that used design to promote genuine customer understanding, a core obligation under the Duty. Journeys that were segmented by customer cohort worked particularly well, reflecting the regulator’s expectation that products and services should be targeted at clearly defined markets. By tailoring interfaces to customer literacy levels, financial experience, and vulnerability profiles, these firms demonstrated compliance with both the Duty’s products and services and consumer understanding outcomes.
The regulator also flagged good practice around customer support mechanisms. Firms that embedded easy access to help, whether through chat functions, FAQs, or quick links to customer service, were seen as delivering against the Duty’s Consumer Support outcome. For vulnerable customers, these features were not optional extras but essential safeguards, ensuring they were not disadvantaged by their circumstances.
The FCA praised some firms’ use of “positive friction” within their journeys. Rather than focusing narrowly on speed, these firms deliberately slowed customers decision making down at key points to help them avoid foreseeable harm. Cooling-off prompts, confirmation screens, or reminders of fees and charges, were all referenced as ways of giving customers the breathing space to reflect and help protect against impulsive or misinformed decisions.
Finally, the FCA commended firms that prioritised steps to improve customer understanding. Plain language, clear layouts, and the use of visual tools like explainer videos, all contributed to improved comprehension. A number of firms also use testing to check whether customers actually understood what they had seen, rather than assuming clarity of design equated to clarity in practice. The regulator flagged this outcome-focused testing as demonstrating the Duty’s shift from processes to results.
Where firms are falling short: Consumer Duty risks
The FCA identified a number of areas where firms risk breaching their Duty obligations:
| Journeys that didn’t align with target market needs | Some firms created interfaces that were intuitive for financially literate customers but confusing or overwhelming for others. This suggested that the design process had not adequately considered the end user. |
| Poor treatment of vulnerable customers | Many platforms made it difficult to disclose vulnerabilities or seek assistance. In some cases, help functions were hidden or only available after a transaction was completed. The FCA was concerned that such design choices increase the risk of foreseeable harm and could be seen as failing to act in good faith, breaching the Duty’s cross-cutting principles. |
| Journeys that prioritised speed over quality | Firms that marketed journeys as “quick and easy” often stripped out vital information, meaning customers were pushed through processes without pausing to absorb risks or costs. While this may improve completion rates, it compromises informed decision-making and jeopardises compliance with the Consumer Understanding outcome. |
| Poorly designed digital nudges | Some firms use of digital nudges – such as pre-ticked boxes, default settings, or highlighted options – risked steering customers toward products or decisions that did not align with their objectives.
Delayed cost disclosure was also a concern, with some digital journeys rushing customers past fee disclosures or steering toward higher-cost options without fair comparison. |
| Limited use of monitoring data | While many firms collected metrics such as journey completion rates or drop-off points, few used this information to assess outcomes. In addition, some firms were overly reliant positive customer reviews as evidence of success. The FCA signalled that this approach fell short of the Duty’s requirement to monitor, test, and evidence whether customers are actually achieving good outcomes. |
Embedding Consumer Duty into digital journeys
The FCA’s findings should be seen as both a warning and an opportunity. With digital design firmly on the regulatory radar, firms need to be in a position to demonstrate that their online journeys are aligned with the Duty. Better digital journeys lead to stronger commercial outcomes by improving customer understanding, increasing conversions, and reducing complaints. The FCA’s review found that firms using clear language, structured layouts, and visual aids helped customers grasp key product information more easily. This reduced confusion and led to fewer disputes, saving firms time and protecting their reputation.
Firms that designed intuitive, supportive journeys, especially for vulnerable customers, saw higher completion rates. Customers were more likely to proceed when they felt informed and confident. Adding “positive friction,” such as prompts to review key terms, encouraged more thoughtful decisions and reduced early cancellations.
Data-driven design also played a role. By analysing where customers dropped off, firms refined their platforms to remove pain points, boosting acquisition and revenue. Transparent design, avoiding pre-selected defaults or misleading incentives, built trust and encouraged long-term loyalty.
Keys steps for firms to take
Use robust segmentation: Firms must define and understand their target markets, then design journeys that reflect the characteristics and vulnerabilities of those customers. This includes language accessibility, usability for customers with low digital confidence, and tailored explanations for complex products.
Reassess use of positive frictions: Rather than seeing it as an obstacle, constructive friction must be used strategically to slow customers at moments of high risk. This ensures that customers have sufficient opportunity to digest key information, directly supporting the Consumer Understanding and Consumer Support outcomes.
Make sure communications deliver: Transparency must also be embedded at every stage. Costs, charges, and risks should be presented upfront in clear, jargon-free language, supported by visual explanations where helpful. Customers must be able to make decisions based on a full understanding of the product’s value and risks, addressing both the Price and Value and Consumer Understanding outcomes.
Ensure governance and monitoring is effective: Boards should set explicit definitions of what “good outcomes” look like for each digital journey. Monitoring should go beyond usability and speed, assessing whether customers emerge better informed, confident, and aligned with their financial objectives. Escalation processes should ensure that where data shows confusion or harm, the journey is redesigned without delay.
How we can help
At Ocorian, we work with firms to embed the Consumer Duty into every aspect of digital design. We begin by mapping current journeys and testing them against the Duty’s outcomes. This provides a clear picture of where journeys support good outcomes and where they risk falling short.
Our team design and implement monitoring frameworks. We help firms move beyond basic conversion metrics to capture meaningful outcome data, such as comprehension levels, customer confidence, and long-term product usage. By embedding this data into governance, we equip senior managers and boards with the evidence they need to demonstrate compliance with the Duty.
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