FCA Consumer Duty & Consumer Understanding
Embedding intelligibility at the heart of outcomes-based regulation.
The FCA Consumer Duty represents a step change in UK financial regulation, placing consumer understanding and fair outcomes at the centre of regulatory expectations. Intelligibility is no longer implicit it is a measurable requirement across communications, products, and contractual terms.
Collaborating to pioneer transformational
AI in Financial Services and beyond
Collaboration with the FCA since 2019. Supported by the FCA Innovation Service and featured in the FCA AI Marketplace. Our consumer comprehension research has informed policy discussions and internal regulatory research.
Amplifi Research
Pioneering research informing policy change
Amplifi Comprehension framework used to inform consultations for supporting consumers pension and investment decisions and the research in understanding targeted support for retail investment
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FCA Consumer Duty: Ensuring Consumer Understanding and Fair Outcomes
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Carbon Emissions in 18 months
What the FCA Consumer Duty Requires
The Consumer Duty introduces a higher standard of conduct for firms, requiring them to act to deliver good outcomes for retail customers. Central to this is the requirement that consumers can understand the information they are given and make effective, informed decisions.
The Duty applies across the lifecycle of financial products and services, from design and pricing to communications and ongoing support. Firms must demonstrate that consumer understanding is actively considered, tested, and monitored.
FCA Principle 12: A firm must act to deliver good outcomes for retail customers.
FCA Principle 12: A firm must act to deliver good outcomes for retail customers.
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Carbon Emissions in 18 months
Understanding Is Not Assumed - It Must Be Evidenced
Under the Consumer Duty, consumer understanding is a defined outcome, not a by-product of disclosure. The FCA expects firms to consider how information is presented, whether it is likely to be understood by the intended audience, and how comprehension can be evidenced.
This shifts regulatory focus from volume of information to clarity, relevance, and usability — particularly for complex products and contractual terms.
- Clear, timely, and relevant communications
- Avoidance of foreseeable harm caused by complexity
- Testing communications for comprehension, not just accuracy
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Energy reduction data operations
Applying an Intelligibility Lens to Consumer Duty
An intelligibility-led approach supports Consumer Duty by assessing whether language, structure, and presentation enable genuine consumer understanding. This includes identifying ambiguity, cognitive overload, and inconsistent terminology that may undermine outcomes.
By analysing communications through a comprehension lens, regulatory expectations around fairness, transparency, and trust can be operationalised more consistently across markets.
By analysing communications through a comprehension lens, regulatory expectations around fairness, transparency, and trust can be operationalised more consistently across markets.
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Increase in bio diversity
Why Intelligibility Matters for Supervision and Outcomes
An intelligibility-focused approach supports the FCA’s supervisory objectives by enabling clearer assessment of how firms meet Consumer Duty expectations. It strengthens the link between regulatory intent, firm behaviour, and consumer outcomes.
By focusing on comprehension rather than disclosure alone, regulators and firms alike can better identify risk, prevent harm, and support fair market functioning.
+62%
Carbon Emissions in 18 months
Consumer Duty as a Foundation for Trust
The FCA Consumer Duty establishes intelligibility as a foundation for fair treatment and consumer trust. As outcomes-based regulation continues to evolve, the ability to assess and evidence consumer understanding will remain central to effective supervision and market confidence.
Our Journey
2019
Joined the FCA Innovation Hub
Received FCA innovation support to refine our thinking on intelligibility and consumer understanding
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Our Journey
2020-21
FCA Digital Sandbox
Tested early AI language models and tooling to address emerging regulatory challenges
Our Journey
2022
Mixed Messages Report
Launched Mix Messages report with StepChange Debt Charity at the FCA event, with a keynote speech from Sheldon Mills (FCA Exec Director)
Our Journey
2023
FCA Regulatory Sandbox
Live testing on consumer understanding - disclosure notices, PCI and default notice
Our Journey
2024
Solicitors Regulation Authority (SRA)
Amplifi collaborated with the SRA in testing intelligibility and improving understanding of regulation / guidance
Our Journey
2024
Ongoing FCA Innovation Support
Amplifi received ongoing innovation support from the FCA to develop layered digital credit contracts
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Our Journey
2025
FCA AI Spotlight
Amplifi was accepted onto the FCA’s AI marketplace. A shop window for leading AI companies operating within financial services
Our Journey
2025
Our research referenced by the FCA
Amplifi Comprehension Framework used in FCA research (CP25/17), and consultation for targeted support
Our Journey
2025
FCA Digital Sandbox
Developing AI models to identify risk in Maths, numbers, tables, charts and cognitive load.
Our Journey
2025
FCA / MAS AI Round Table
Amplifi invited by FCA AI lab to showcase our Intelligibility Risk Platform to the Monetary Authority of Singapore (MAS).
Our Journey
2025
HMT Consumer Credit Act Consultation
Amplifi regulatory sandbox work and evidence on consumer understanding for Pre Credit Info (PCI) and Default notice used and mentioned in the consultation.
Intelligibility is not an enhancement to
regulation - it is how regulation works
in practice.
Amplifi & The FCA
Over a six-year period, Amplifi Global have received a range of Innovation Service support tailored to changing needs across their full innovation lifecycle.
1. Amplifi received support via Innovation Pathway, including an informal steer on precontractual disclosures and adequateexplanation requirements in CONC 4.2 and CONC 7.3.
2. Amplifi concept development in the Digital Sandbox, followed by live test with a regulated credit provider in the Regulatory Sandbox, to ensure alignment with Consumer Duty principles.
3. In collaboration with Universities, the firm have conducted research into consumer comprehension, which has informed FCA policy discussions and contributed to internal research.
2. Amplifi concept development in the Digital Sandbox, followed by live test with a regulated credit provider in the Regulatory Sandbox, to ensure alignment with Consumer Duty principles.
3. In collaboration with Universities, the firm have conducted research into consumer comprehension, which has informed FCA policy discussions and contributed to internal research.
Significant progress in product development with FCA guidance
The tool's effectiveness was validated using Regulatory Sandbox and supporting research
Results will support engagement with lenders aiming to meet Consumer Duty standards
Explore Regulatory blogs
The Knowledge Hub is Amplifi’s home for blogs on research, insights, and tools that put consumer understanding at the centre of compliance, finance, law, and AI.
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