Consumer Duty: Communications Testing & Risk Identification

 

How to identify risks of harm and improve customer understanding across complex financial communications. 


Working on behalf of several clients who needed to meet Consumer Duty requirements across a range of financial products, including protection, investments, pensions and mortgages. This involved testing long and complex customer-facing documents such as terms and conditions, product brochures, policy summaries and Q&A materials with a broad spectrum of customers, including vulnerable groups.


A white hexagon outline containing a maze

The challenge

Meeting Consumer Duty obligations requires more than demonstrating that information has been provided; firms must show that customers genuinely understand the information and are not at risk of harm. 

 

The challenge was to move beyond stated understanding to:
• Assess how customers actually interpret complex financial information
• Identify where language, structure or presentation creates confusion or misunderstanding
• Understand how vulnerability affects comprehension and decision-making
• Pinpoint areas where customers may be at risk of harm across different product categories

This was particularly critical given the length and complexity of the materials being tested, and the diversity of customer needs and capabilities.

The approach

We conducted primary qualitative research using in-depth interviews with target consumers, explicitly including vulnerable customer groups.

One-to-one depth interviews with consumers across protection, investment, pension and mortgage markets
 

Inclusion of customers experiencing different forms of vulnerability, including: 

• Reduced financial capability
• Ill-health or disability
• Life events causing vulnerability (e.g. job loss) 

 

Structured techniques designed to get beyond claimed understanding, including: 

• Task-based comprehension testing
• Exploration of decision-making and potential misinterpretation
• Identification of emotional and cognitive pressures

The approach allowed us to drill down into both initial reactions and considered responses, testing multiple executions and messages in detail. 

A grey hexagon outline containing two people and a cog
A grey hexagon outline containing a star and a tick

The result

The research provided clear, regulator-ready insight into how customers engage with complex financial communications.

Key outcomes included:
• Identification of specific areas where customer understanding breaks down
• Clear evidence of where and how vulnerable customers are disproportionately affected
• Practical recommendations to improve clarity, accessibility and fairness

The findings enabled clients to strengthen compliance with Consumer Duty while improving customer outcomes across multiple product lines.