FCA Consumer Duty Review: Digital Design in Customer Journeys – Lessons for All Firms
- Simon Roberts
- Aug 13, 2025
- 3 min read
The Financial Conduct Authority (FCA) has published the findings from its multi-firm review of digital design in customers’ online journeys, part of its ongoing work to monitor and share how firms are embedding the Consumer Duty.
While the review focused on consumer credit providers, the FCA has made it clear that the findings are relevant to all regulated firms with a digital presence — including those using apps, online platforms, or other digital channels to acquire and serve customers.
At K2 Regulatory Consultants, we see this as a timely reminder that digital design is not just a user experience (UX) concern — it’s a regulatory requirement under the Consumer Duty to deliver good outcomes.
Why the FCA Conducted the Review
The FCA has previously examined the impact of harmful digital practices — such as “sludge” and deceptive design — on consumer decision-making. This latest review looked specifically at:
How firms acquire customers through digital channels.
Whether design supports or undermines good outcomes.
How data from digital journeys can be used to improve customer understanding and decision-making.
Key Themes from the FCA’s Findings
1. Design Journeys to Meet Target Customers’ Needs
Firms must ensure that:
Digital journeys reflect the needs and characteristics of their target market, including customers with vulnerabilities.
Frontline staff are involved in the design process to feed in real-world insights.
Customers can easily disclose vulnerabilities and request support.
2. Use Positive Friction to Drive Good Outcomes
Positive friction — moments in the journey that slow customers down to think — can:
Give customers time to absorb product information.
Reduce the risk of rushed, unsuitable decisions.
Encourage informed choice, especially for complex products.
3. Clear, Accessible, and Balanced Information
The FCA found good practice where firms:
Present key information (fees, charges, risks) clearly and promptly.
Use visual aids such as images or videos to explain complex features.
Avoid design that exploits consumer biases (e.g. pre-selected defaults or over-promoted “featured” options).
4. Test, Test, Test
Ongoing testing is critical:
Check whether product descriptions and terms are understood across different customer groups.
Test on multiple devices and operating systems to ensure consistency.
Use data analytics to identify journey points where customers drop out or misunderstand information.
5. Leverage Data for Oversight
Digital journeys produce significant amounts of behavioural data. The FCA expects firms to:
Analyse this data regularly to identify design flaws and improve outcomes.
Go beyond customer satisfaction scores or online reviews — these alone are insufficient to assess Consumer Duty compliance.
Incorporate MI from both analytics and frontline feedback into governance processes.
K2’s Perspective
The FCA’s review reinforces that digital design is a regulatory risk area. For firms, this means:
Embedding Consumer Duty principles into UX design from the outset, rather than retrofitting fixes.
Involving compliance early in product and platform development.
Viewing journey analytics not just as a marketing tool, but as a conduct risk management tool.
Even if you are outside consumer credit, the FCA’s expectations apply if you have any digital customer touchpoints — from investment platforms to payment apps.
How K2 Can Help
We can support you in:
Mapping your current digital journeys against Consumer Duty requirements.
Testing language, design, and friction points with real customer groups.
Analysing your journey data to identify where customer understanding or decision-making may be compromised.
Ensuring governance frameworks capture insights from both data and frontline experience.
The FCA has signalled it will continue to monitor digital design closely — firms that act now will be better positioned to evidence compliance and avoid costly remediation.
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