At its core, the message is a familiar one: customers should receive the information they need at the right time, and in a way they can understand. This means information must be fair, clear, and not misleading, and designed to support effective, timely and informed decision-making.

The review is a useful reminder that consumer understanding is not just about what information is provided, but how, when and where it is presented. It also gives a clearer picture of what the FCA sees as good practice, and where firms may fall short.

What good practice looks like

The FCA highlights several features that can underpin a strong approach to consumer understanding:

• Use insight to identify where consumers struggle. Firms should draw on a range of sources to understand where consumers are getting stuck or confused. This can include call listening, complaints, chat transcripts, website analytics, drop-off data (customers who start but do not complete a specific process) and surveys. Review this evidence regularly to prioritise meaningful improvements, rather than cosmetic tweaks.
• Test communications with real customers. Use proportionate methods such as surveys, comprehension checks, A/B testing and feedback from frontline interactions to assess whether changes to customer comms are genuinely improving understanding. Adapt comms further if needed based on the results.
• Communicate clearly, simply and accessibly. The FCA points to plain language, clear structure, visual hierarchy and layered content as good communication design. Essential information should be upfront, with key risks and exclusions surfaced early rather than buried in the detail. Firms should also ensure that information is available in different formats to meet customer needs.
• Design journeys and tools that support understanding. Well-designed customer journeys can help people engage with information and make better decisions. This could be calculators, videos, walkthroughs or summaries, any of which should be tested and refined based on user evidence to make sure it genuinely helps customers.
• Support vulnerable customers. An effective approach is to identify customer needs early, adapt communications where needed, and embed vulnerability considerations into governance, training and testing. This includes testing with vulnerable customers and ensuring accessibility requirements are considered throughout a customer journey.
• Clear, fair and balanced financial promotions. Promotional content should be balanced, accessible and easy to understand. Risks and benefits should be given equal prominence, jargon should be avoided, and firms should check that consumers understand key terms properly (such as eligibility criteria and limitations).
• Governance and oversight. Firms should maintain defined governance, review management information regularly, track actions, and make sure decisions lead to improvements. Oversight should be embedded into everyday business processes, and not exist as a separate compliance exercise.

A closer look at innovation and communication design

Innovation and communication design play a central role to help customers understand information, navigate key decisions and avoid causing foreseeable harm. The FCA says that firms should design communications deliberately, using clear structures, plain language, layering, and accessibility principles – they should not assume that customers will interpret information in the way the firm intended.

Layering is about sequencing information so consumers see the most important points first, with additional detail provided at the right stage of the journey. It can help firms communicate clearly without overwhelming consumers with long and complex documents, while still making fuller information available where needed.

Good practice involves:

• Presenting essential information upfront so customers see the most important messages, risks or actions first.
• Staging information across the consumer journey, rather than delivering everything in one long or complex document.
• Aligning information to decision points, so customers receive detail when it’s most relevant.
• Making the path to additional information clear, so customers can explore further detail without losing sight of the essentials.
• Testing these design changes to confirm improved customer comprehension.

Effective simplification is not just about cutting words, but amount making content itself easier to understand so customers can act on what matters. In practice, this might include:

• Using plain language instead of technical or legalistic wording.
• Defining necessary technical terms clearly rather than assuming prior knowledge.
  Focusing each piece of content on the essential message, rather than trying to say everything at once.
• Making actions or next steps explicit, so consumers understand what they need to do.

Tools and prompts can also support consumer understanding alongside content design. Testing these tools can ensure they support comprehension and allow consumers to move through a journey with more confidence. Example features might be:

• Calculators or walkthroughs to help customers understand processes.
• Short videos, interactive diagrams, and clickable FAQs to break down complex information at a customer’s own pace and make it easier for them to understand key steps or risks.
• Chatbots and virtual assistants to answer questions instantly or guide customers through a journey step by step.

Positive friction is about introducing deliberate, short pauses in the customer journey that help consumers slow down and avoid harmful snap decisions. Its purpose is not to obstruct the journey, but to encourage reflection where speed may lead to poor outcomes. This could be introducing real-time prompts into the customer journey to prevent common mistakes, such as warnings during payment journey to alert about potential scams, or messages that explain why certain information is needed.

Designing for accessibility and diverse needs

Research has found that 1 in 7 adults have literacy skills at or below those expected of a 9 to 11-year-old. The FCA’s Financial Lives Survey also found 17.7 million adults (34%) have poor or low levels of financial numeracy.

Firms perform well when they tailor designs for customers with low digital confidence, lower financial capability, sensory impairments, or different communication needs. This includes:

• Adapting formats for consumer requirements, such as introducing improved colour contrast, meaningful alt-text or layouts tested for screen readers.
• Improving readability by rewriting content in plain language.
• Testing accessibility features with users who face additional challenges to understand what refinements or additions may be required.

What doesn’t work?

Surface level changes, shorter wording, new icons or colour changes without improving clarity, sequencing or prominence of key information – the FCA still found that customers missed or misinterpreted core points.

Several firms did not test communications with customers or relied on very small, unrepresentative groups. Some assumed an absence of complaints meant that communications were clear.

Presenting the same design and format to all customers without considering customers in vulnerable circumstances who may have accessibility needs, language preferences or lower digital confidence created foreseeable barriers to understanding.

Some firms continued to produce long, dense documents without summaries, visual hierarchy or navigational cues. Customers were expected to locate critical information without support, increasing the likelihood of misunderstanding. Firms committed to using jargon-free and intelligible language but had limited evidence to show this had been embedded in communications to customers.

Takeaways

The examples of good and poor practice in this report are provided to help firms learn from each other and support improvements in consumer understanding across the market. They do not create new regulatory requirements, and firms do not need to adopt every example. However, firms should use these insights to assess their own approach and identify where improvements may be needed to meet their obligations under the Consumer Duty.

The learnings are not just helpful in the financial services context but any context where you are providing information to consumers.  In the past Ofcom has published similar insights, and the CMA recently published draft guidance on avoiding unfair terms in consumer contracts, which also touches on the design of consumer-facing materials and says that drafting should be clear, concise and designed for consumer understanding, with key information made visible early on in the sale and purchase process. All the regulators are taking this seriously.