FCA Review: Digital Design in Customers' Online Journeys – Good Practice and Areas for Improvement
On 31 July 2025, the FCA published a review on the design of digital acquisition journeys and their impact on customer outcomes. This review is part of the FCA’s commitment to sharing insights on how firms are embedding the Consumer Duty and it emphasises the importance of designing digital journeys that promote good customer outcomes and meet the needs of diverse customer groups.
Whilst the findings are based on a review of digital loan processes and of direct relevance to consumer credit firms, the FCA considers that they may be of interest to all regulated firms with a digital presence. Please see our analysis and summary of the key findings below, including examples of good and poor practices as identified by the FCA.
Key Findings
The Consumer Duty requires firms to monitor and regularly review customer outcomes. Digital journeys generate significant valuable data that can help firms understand and improve customer interactions. For example, analytics can identify high dropout points, such as when customers are asked to enter payment details. The FCA highlights both good practices and areas for improvement across four key areas: Design Aspects, Different Customer Groups, Testing and Quality Assurance, and Management Information and Oversight. We have summarised the key points here, please see further below for our more detailed analysis.
A) Design Aspects. The design of digital platforms can significantly influence customer behaviour, understanding and decision-making. While well-designed platforms can support good outcomes, poor design can lead to rushed or uninformed decisions that may not align with customers' best interests. Good practices including clear layouts, plain language, and the use of visual aids, while areas for improvement include addressing biases in layouts and adding positive friction to support informed decisions.
B) Different Customer Groups. Firms should design digital journeys to meet the diverse needs of their target market, including vulnerable customers, by tailoring journeys for different customer groups and providing additional support where necessary. Firms should test how well vulnerable customers can disclose their needs and ensure that relevant support channels are effective.
C) Testing and Quality Assurance. Testing digital journeys for customer understanding and outcomes is essential, with good practices including language testing and feedback integration, while areas for improvement involve ensuring clarity in complex products and addressing device compatibility issues.
D) Management Information and Oversight. Firms should leverage data analytics to monitor customer outcomes and improve digital journeys, avoiding over-reliance on online reviews as a sole indicator of success.
- Consumer Duty Expectations: Firms are encouraged to consider how their digital journeys affect customer understanding and decision-making when applying for credit. As such, firms are expected to design digital journeys that promote good customer outcomes, ensuring customers understand products and make decisions in their best interests.
Next Steps for Firms: What Actions Should You Take?
For Consumer Credit Firms:
- Assess your firm’s practices against the FCA’s good practice examples.
- Identify any gaps and develop a clear plan to address them, or provide a robust justification for why no action is required.
For All Firms Subject to the Consumer Duty:
- Reflect on whether there are lessons from the FCA’s review that can be applied to your customer journeys.
- Remember, the Consumer Duty is not a “once and done” requirement. It demands a continuous improvement mindset, encouraging firms to refine their approaches and practices to consistently deliver good customer outcomes.
- Firms should proactively make improvements aligned with good practice and address any issues that could pose risks of consumer harm.
Next Steps for the Industry:
- The FCA will continue to monitor firms’ approaches to digital journeys and app design, ensuring alignment with the Consumer Duty.
- Firms are encouraged to regularly review and enhance their digital platforms to ensure they deliver positive customer outcomes.
If you would like our support in reviewing your digital journeys in light of the FCA’s feedback, please don’t hesitate to get in touch. We are already working with several firms to help them meet these expectations.
Design Aspects
Good Practices
1. Design for Different Groups:
- Firms should tailor digital journeys to meet the needs of various customer groups within the target market and provide adequate support for all customers, including those with characteristics of vulnerability.
2. Support for All Customers:
- Good platform design ensures that customers, including those dealing with non-standard issues or customers acquired through different channels (such as third-party referrals), receive sufficient support to understand products and services.
3. Use of Friction:
- Introduce positive friction to encourage customers to take time to make informed decisions, particularly when applying for credit. Firms should be proactive in identifying other complex products that might benefit from similar frictions in customer journeys.
4. Clear Layout and Language:
- Use plain English, short sentences, and clear layouts to aid understanding.
- Provide visual aids, such as images and videos, to explain key product information.
5. Feedback and Testing:
- Involve frontline agents in the design process to incorporate customer interaction insights.
- Conduct testing and quality assurance to ensure digital journeys lead to good customer outcomes.
Areas for Improvement
1. Not Meeting Customers' Needs:
- Some firms fail to design journeys that meet the needs of their target customers, particularly those requiring additional support or alternative communication channels.
2. Failure to Support Vulnerable Customers:
- Digital journeys often fail to identify and support customers with vulnerable characteristics. Firms should test how easily customers can disclose vulnerabilities or request additional help.
3. Lack of Friction:
- Overly streamlined journeys may lead to rushed decisions. Firms should consider adding friction to allow customers time to review and understand key information.
4. Bias in Layouts:
- Design choices, such as pre-selected defaults or promotional incentives, can nudge customers towards certain decisions, potentially exploiting biases and leading to poor outcomes.
5. Lack of Product Information:
- Key details, such as fees and charges, are not always presented clearly or in a timely manner, hindering customer understanding.
6. Speed Over Customers' Interests:
- Firms should consider how the speed of journeys impacts customer outcomes. For example, marketing credit applications as quick or time-limited can create unrealistic expectations and lead to decisions that are not in customers' best interests.
Different Customer Groups
Good Practices
1. Understand Your Target Market:
- Firms should conduct target market analysis to understand the needs of different customer groups, including those who need additional support, with vulnerabilities or acquired through different channels, such as third-party referrals.
2. Adequate Support for All Customers:
- Firms operating solely through a digital platform ned to ensure that platform can meet the support needs of all customers, including those dealing with non-standard issues or requiring additional help.
3. Identify Vulnerable Customers:
- Use digital channels to identify customers with vulnerabilities and test the effectiveness of support channels through customer insights and testing.
Testing and Quality Assurance
Good Practices
1. Appropriate Language:
- Firms should extensively test the language used in websites, apps, and promotions to ensure clarity and understanding.
2. Easy to Understand:
- Assess how easy communications are to understand for customers.
3. Data and Feedback:
- Use quality assurance, data, and frontline agent feedback to improve digital journeys and customer support.
Areas for Improvement
1. Failure to Test Key Details:
- Firms can test whether customers fully understand key product information, such as fees and features.
2. Complex Products:
Accessibility software is often used to review the language used in apps and websites. While this simplifies language, it does not always improve customer understanding, particularly in complex products, as stated in FG22/5: ‘Final non-Handbook Guidance for firms on the Consumer Duty’ (July 2022) (see 4.17).
3. Poor Understanding of Products:
- Firms can test whether end-to-end journeys enable customers to fully understand products and their features, including how apps operate on different devices or operating systems.
4. Lack of Friction:
- Even in quick journeys, firms should introduce appropriate friction to give customers time to read and understand information.
Management Information and Oversight
Areas for Improvement
1. Analyse Data on Customer Journeys:
- Firms should analyse data to identify where customers are advancing too quickly and missing key information or support.
2. Use Multiple Indicators to Measure Success: - The review highlights that positive online reviews are not sufficient indicators of good customer outcomes. Firms should not rely solely on online reviews but use a range of indicators to understand customer outcomes across their base.
