Under the Consumer Duty, firms should not assume that customers will understand information simply because it has been provided. The FCA expects communication design to be intentional, structured and tested, rather than relying on how information is interpreted in practice.
Good practice involves designing communications in a way that actively supports understanding. This includes using plain language, clear structure, visual hierarchy and logical flow so that customers can easily identify the most important information. Key points such as risks, exclusions and limitations should be clearly presented upfront, rather than being hidden within lengthy documents.
Layered communication is also an effective approach. This means presenting essential information first, with the option for customers to access additional detail if they need it. This helps prevent information overload while still ensuring customers who want more detail can access it easily.
Firms should also consider how customers interact with communications across different channels. Information should remain clear and consistent whether accessed via mobile, online platforms or paper-based formats. The FCA’s expectation is that communications should be designed with real customer behaviour in mind, not just regulatory compliance.
