Thursday, August 28, 2025
Consumer Duty at two years: FCA digital journeys and complaints
Two years on from the introduction of the FCA’s Consumer Duty, one message is clear: this is not a one-off compliance exercise but an ongoing expectation. It’s a long-term regulatory shift; firms must now also prove that they deliver good outcomes for customers. This means raising the bar once again for Consumer Duty and complaints handling across regulated industries.
The FCA’s latest guidance on digital design looks at how customer journeys are structured. From how terms and conditions are displayed to the way customers navigate online forms, design choices directly affect whether people understand what they are buying. And when customers don’t understand, they complain.
What is the Consumer Duty Rule in the UK?
The Consumer Duty requires firms to adhere to three cross-cutting rules:
To act in good faith - being honest and fair toward customers
Avoid foreseeable harm - taking proactive steps to prevent harm to customers
Enable customers to pursue their financial objectives - providing the necessary information and support for customers to make informed decisions
These principles are reinforced through four outcomes:
Products and services must meet genuine customer needs
Pricing must represent fair value
Customers must be able to understand what they are agreeing to
Customer support must be easily accessible and effective
Many formal complaints originate from the fact that customers didn’t fully grasp the terms, risks, or costs upfront. Under Consumer Duty, this is no longer acceptable.
What the FCA found in digital journeys
The FCA’s review of digital journeys sets out clear contrasts between good and poor practice:
Good practice - using plain language, clearly displaying costs and terms, and allowing customers to pause or save journeys before making a decision
Poor practice - hiding fees, over-complicated navigation, or nudges that push customers into unsuitable products
As the FCA puts it,
“Firms should design customer journeys that support informed decision-making rather than exploit behavioural biases.”
Design is so much more than getting the aesthetics right. It's a regulatory expectation that firms build digital processes in line with Consumer Duty.
Why do poor digital journeys lead to complaints?
When customers encounter unclear terms, hidden costs, or confusing digital flows, the result is predictable: dissatisfaction and complaints. These cases then escalate to the Financial Ombudsman Service (FOS), creating reputational and financial risk for firms.
Complaints aren’t random noise. They’re data signals about where journeys fail. When firms ignore them, they lose the feedback loop needed to prove Consumer Duty compliance.
Complaint handling process under Consumer Duty
The DISP complaint handling rules already set the baseline for complaint handling; however, under Consumer Duty, firms must show how they learn from complaints. This effectively creates the Consumer Duty complaint process that regulators expect to see in action.
The five broad stages are:
Acknowledgement – customers must be informed quickly that their complaint is being reviewed
Investigation – gathering facts, evidence, and context to understand the issue
Resolution – deciding on the appropriate outcome, including compensation and remediation
Response – providing a clear final response in plain language, within regulatory timelines
Learning and feedback – feeding insights back into products, services, and digital journeys across the firm
It's stage five that the FCA is watching closely and puts responsibility on firms to use complaints data as a feedback loop. Consumer Duty is not satisfied by just closing a case on time and in a fair and consistent manner.
Looking for a framework beyond process? Our 5 Cs of complaint handling guide explores the principles that drive stronger outcomes.
Practical steps for complaint teams
To align with Consumer Duty and the FCA’s digital design focus, complaint teams should:
Track complaint root causes tied to digital journeys, such as unclear fees or confusing online flows
Share management information (MI) complaint data with appropriate teams, including digital and product, to highlight recurring issues and build a clear evidence trail of actions taken to address them
Embed complaint insights into Consumer Duty dashboards so leadership can evidence changes
Escalate systemic patterns early to prevent harm before the regulator steps in
Complaint data provides firms with unique visibility into where their digital journeys may be failing customers. Used well, it turns risk into a roadmap for improvement.
How technology supports Consumer Duty
We've now established that firms must show how their complaint handling processes link to expectations of the Consumer Duty. The use of manual spreadsheets and siloed systems makes this almost impossible to do at scale.
Complyr’s complaint case management software gives regulated complaint teams structured workflows, root cause analysis, Consumer Duty insights, and visibility to share insights across all departments of the business. This doesn’t just speed up resolution and save costs; it’s showing commitment to acting on customer feedback, proving to regulators that the firm is acting in line with Consumer Duty.
Complaints aren’t only about resolving today’s issue. They are the most reliable signals of tomorrow’s compliance risks. With the right tools, they can be your strongest safeguard for regulatory compliance and customer trust.
The FCA is also testing how AI could support these processes. Our FCA AI Sprint blog explores how complaint handling is becoming the proving ground for responsible AI.
Consumer Duty is an ongoing journey, not a destination
The FCA’s digital journey review makes one thing clear: firms must move beyond promises on paper. Two years in, Consumer Duty is demanding how well you can prove outcomes are being delivered.
Complaint data is the richest source of evidence you have about your digital journeys, and as such, it should be used as your navigation tool. Firms that treat it as strategic intelligence, rather than operational admin, will be the ones staying ahead of FCA scrutiny and building long-term customer trust.