On 31 July 2025 the Financial Conduct Authority (FCA) published its findings on the design of firms’ digital acquisition journeys and customer outcomes.

Background

The FCA explained that it is publishing this work as part of sharing information on how firms are embedding the consumer duty. The FCA set out that, following its research into digital design and sludge practices, it had conducted further work on this with a small number of firms, which focussed on the acquisition of customers and delivering good customer outcomes, and that its findings were based on this work.

Findings

The FCA highlighted that, while the findings of the review itself related to consumer credit providers, examples of good and poor practice might be of interest more broadly to firms with a digital presence.

Key areas of good and poor practice for firms to consider included:

• Design aspects: The FCA explained that some firms had carefully considered the design of digital platforms, including how to meet the needs of different groups and support vulnerable customers. The FCA also set out examples of other good practices such as adding ‘positive friction’ (i.e. to slow customer decision making), using clear layouts and language, using imagery, and getting feedback on and testing for good outcomes. However, the FCA also explained that some firms could improve customer journeys by further considering different customer groups’ needs, by adding friction and considering how journey speed can affect customer outcomes, as well as ensuring that layouts do not exploit biases and sufficient product information is given.

• Customer groups: The FCA noted that good practice in relation to customer groups included firms’ understanding their target market, ensuring that adequate support is given to all groups of customers such as whether customers need additional support or are vulnerable, and firms’ reviewing the effectiveness of these support channels.

• Testing and Quality assurance: The FCA highlighted that good practices included testing for use of appropriate language and whether communications were easy to understand, as well as quality assuring customer journeys using feedback from frontline agents. However, the FCA also set out that, to improve their approach, firms should test key product information for customer understanding, ensure that there is an appropriate amount of friction within the customer journey, and should test how good outcomes are achieved in respect of different customer groups.

• Management information and oversight: Finally, the FCA explained that, to improve oversight of customer journeys, firms should analyse data received in relation to those journeys and customer outcomes, and should utilise multiple indicators to measure success.

Next Steps

The FCA will continue to monitor firms’ approaches to digital journeys and app design, as well as how the design of digital products and services offer the required level of support and customer understanding under the Consumer Duty.