In July 2025, the Financial Conduct Authority (FCA) published the findings of its review into digital design in customer acquisition journeys, with a particular focus on the consumer credit sector.
For most people, the first interaction with a financial product now begins online. The way these digital journeys are designed has a direct impact on how customers understand products, weigh up risks, and make decisions. With the Consumer Duty now fully in force, the FCA is paying close attention to whether digital channels are helping or hindering customers in achieving good outcomes.
In this article, we’re summarising the good and poor practices the FCA has identified, and what payments, and e-money firms can do to improve their customer journeys.
Digital Design Under the Spotlight
Digital interfaces are an integral part of a firm’s regulatory obligations. The FCA’s review shows how design features, from the way options are ordered, to the presence (or absence) of friction, can influence customer choices.
This means that user experience (UX) and compliance are increasingly interconnected. A customer journey that makes it too easy to rush into a decision, or hides key information, will not only create poor customer outcomes but may also breach Consumer Duty requirements.
The regulator is therefore urging firms to move beyond treating digital design as a marketing or technical exercise. Instead, it must be embedded within governance and compliance frameworks, tested against real customer behaviours, and monitored to ensure it continues to deliver fair and transparent outcomes.
Good Practices Identified
In its recent report, the FCA highlighted several positive approaches that firms can adopt when designing their customer journeys:
- Using friction appropriately: introducing small pauses or additional steps so that customers have time to reflect before committing.
- Clarity and accessibility: presenting information in plain language, avoiding jargon, and using layouts that make products easy to understand.
- Considering diverse needs: designing with vulnerable customers in mind, ensuring that services are inclusive and accessible.
These practices align with the Consumer Duty’s requirements to support customer understanding and deliver good outcomes.
Areas of Poor Practice
However, the review also identified concerning design choices that risk undermining fair outcomes:
- Overly persuasive features: nudges, defaults, or urgent prompts that may pressure customers into unsuitable decisions to meet sales objectives, rather than Customer Duty obligations.
- Insufficient support for vulnerable users: lack of accessible formats, tailored assistance, or recognition of additional needs.
- Failure to test and monitor: limited evidence that firms are assessing whether their digital journeys actually work for customers in practice.
Such practices could bring firms into conflict with the FCA’s expectations under the Consumer Duty, particularly where foreseeable harm is not being addressed.
FCA Expectations Going Forward
The regulator expects firms to:
- Review and refine digital journeys regularly, ensuring they remain fit for purpose as customer behaviour and technology evolve.
- Test journeys from the customer’s perspective, including those of vulnerable groups, to confirm they are transparent and fair.
- Align digital design with the Consumer Duty, embedding good outcomes into product and service delivery.
The Last Word
By acting now to review and improve digital journeys, firms can not only reduce regulatory risk but also build greater trust with customers.
API Compliance can assist with Consumer Duty reviews, digital journey assessments, and the development of compliance-aligned customer experience strategies.
If you would like to discuss how to strengthen your approach, please get in touch using the contact form below.
