The FCA, regulator for c.50,000 financial services and markets in the UK, published a finalised Consumer Duty paper in July 2022 bringing new guidelines to improve customer and user experience in UK financial services.

An overarching pyramid diagram showing the Consumer overarching principle.

The Consumer Duty aims at a higher level.

A holistic, sustainable approach

We believe that accessible design is the best design to create the best user experiences. Technologies developed through the lens of the end user that were specifically developed for people with different types of disabilities have ended up benefiting people without them.

For example, during 1999, T9 Predictive texting which was originally developed for users with motor issues, sped up how we all send and receive SMS messages.

The need for a service design approach

The Consumer Duty principles impact all UK retail financial institutions that serve the general public. The principles are quite broad and contain various commercial, financial, operational and legal implications for banks, which impact the interconnected and complex physical and digital products, services and processes they provide. This article will set out the Design approach and principles we can draw out of our analysis of the Consumer Duty paper.

Consumer Duty Standards with 6 points that are specified in the article.

Our approach on how to meet the Consumer Duty user experience and customer experience principles through various steps including analysis, tiering, setting standards and an inclusive design approach.

Gap analysis

This is the usual starting point for most banks when it comes to Consumer Duty: assessing current performance to determine if the new requirements and objectives are already being met and, if not, what steps need to be taken to meet them. Here, the bank will need to conduct and/or scrutinise any work done so far on Consumer Duty work internally in accordance with the FCAs final rules.

Tiering of services

As part of the gap analysis, organisations will need to audit their existing products, services and variations of them and prioritise which ones contain criteria that fail to comply with the final rules and best practice.

Consumer Duty ultimately means that a bank should create a “healthier financial service system where consumers are informed” and it ‘adapts and delivers’ in interests of consumers.

Channel and technology standards

Customers leverage a myriad of channels to engage with banks products and services. Most banks will take an omni-channel approach when thinking about good outcomes. Forward thinking banks will need to consider where vulnerable user requirements come into play when engaging across different channels.

What the FCA wants to see is ‘good outcomes’ across channels.

Data approach

With Consumer Duty, banks will need to redefine the meaning of data. In the FCAs words: “Under the Duty, firms will need to assess and evidence the extent to which and how they are acting to deliver good outcomes. Combined with our more data led approach, this should enable us to more quickly identify practices that negatively affect those outcomes and to intervene before practices become widespread.”

Design standards

Based on the pillars of inclusive design and the data approach, it is key to define the functionality and content design standards across channels to ensure that products, services, and features are designed in the most accessible way possible.

Screenshot of the Bank of England Design Guidelines.

Cyber-Duck's design guidelines for The Bank of England.

Inclusive design

The FCA really wants to see how information empowers consumers of banks by ‘simplifying the complex’ as much as possible. It also wants to see a complete end to “selling misleading products”, “lack of fair value” to customers and see “an end to poor customer support” — hopefully most organisations will conduct gap analysis as described above to nip anything like this in the bud — it is 2022, and no respectable financial services institution should knowingly mislead any customer after the various mis-selling scandals!


Consumer Duty contains several essential components that are important from a Service Design perspective as Service and UX Designers have the opportunity of refactoring journeys to ensure they are compliant. Channel choice is one. The FCA says that: “Firms should also have processes in place to support those with other characteristics of vulnerability … for example, by having a clear way for consumers with a hearing or visual impairment to request communications in a format that meets their needs.”

The 5 Pillars of Digital Inclusion: Accessibility, Connectivity, Affordability, Literacy and Safety.

The 5 pillars of Digital Inclusion.

Testing products and services on an ongoing basis to ensure they comply is also critical. A big part of products and services contain communication modules and functionality. This include ’app modals’, push notifications, geofencing features, phone calls, chatbot support and of course email communication. Testing all communication around key products and services with vulnerable users is particularly beneficial as it could reveal key gaps in user satisfaction and fulfilment and uncover numerous issues and errors not only with the communication itself but with overarching utility and functionality.