For financial services firms, complying with the FCA's Consumer Duty presents a dual challenge. The first is operational: how to ensure you're delivering good outcomes. The second, more critical challenge is evidential: how do you prove it to the regulator?
The principles of Consumer Duty - protecting customers from harm and communicating clearly - are, in essence, the principles of good User Experience (UX). This natural overlap means that the tools and methodologies of UX provide a robust, practical framework for not only meeting but also evidencing your compliance.
The duty itself is broad. To make it manageable, you must translate it into a tangible, measurable process.
We developed a bespoke heuristic scorecard for this purpose. By breaking down the FCA's core principles into a scorable framework, we can conduct a systematic review of any customer touchpoint, from an email or direct mail piece to a digital ad.
Further to this, we augment the scorecard with UX methodologies including inclusive usability testing, content testing, and attention mapping.
This whole process provides unambiguous, actionable outputs. It gives our clients a clear report detailing what is working well, what could be improved, and what might be fundamentally broken. This allows them to make targeted, effective changes and, crucially, track improvements over time.
The FCA has been explicit: firms must be able to evidence the steps they are taking to ensure good outcomes. This requires a continuous, iterative approach to testing and improvement - not a "one and done" project.
This is why human-led usability testing remains a critical part of the process. When dealing with high-stakes financial products like mortgage agreements or credit cards, the risks are significant. The complex experiences of vulnerable customers cannot yet be reliably simulated by AI, but our approach can still evolve. To gather the robust evidence required by the FCA and truly understand the customer experience, we must always include conversations with real people, enhanced with AI to provide scale and diversity that complements our human-led approach.
By embedding a systemised UX process into your operations, you move beyond a subjective assessment. You create a reliable evidence framework that protects your business, satisfies the regulator, and delivers genuinely better, fairer outcomes for your customers.