Digital design in customers' online journeys

FCA good practice and areas for improvement

What’s this about?

The FCA has published a helpful piece of work on good practice and areas for improvement in relation delivery of good customers outcomes on the design of digital acquisitions journey, especially as more firms look to digitalise their customer journeys.

Our Senior Compliance Manager of Financial Regulation, Nikesh Shah says...

“As more firms enhance their digital offerings, this FCA publication is a timely reminder that delivering good outcomes through the design of digital customer journeys is an expectation for all firms.”

Who this applies to

Even though it is primarily aimed at consumer credit providers, it is relevant to all regulated firms with a digital presence.

Good practices identified

Design for different customer groups within the target market by using firms target market analysis to better understand needs of their customers
Support for all customers, including vulnerable ones which includes the digital design, building in consideration of how non-standard issues will be dealt with or customers with characteristics of vulnerability will be identified
Use of friction to encourage thoughtful decision-making
Use of visual images and videos to explain key information about products and how they work
Testing for good outcomes to ensure customer understanding via extensive testing of language, feedback from frontline agents and the use of quality assurance and data used to improve design

Areas for improvement identified by the FCA

Designs that don’t meet customer needs or fail to support vulnerable users because the firms do not test whether good outcomes are achieved for different customer groups
Biased layouts e.g. customer not being able to fully view pages to access different settings or insufficient product information may result in the customer not understanding the product or its features.
Prioritising speed over customers having the opportunity to understand the product or whether it is right product for them, as such the lack of friction leading to rushed decisions
Failure to test key communications or product details such as customer understanding of key product information such as fees or features or limitations
For complex products the simplified language via possibly accessibility software does not improve customer understanding for the narrow target market

Use of data and oversight

Firms should use analytics to monitor customer journeys and identify pain points (e.g., high dropout steps).
Multiple indicators should be used to assess success and improve outcomes

Next steps for firms to consider

The FCA are going to continue monitor digital journey design, so firms should be prepared for further engagement on how their digital journeys are designed to support delivery of good customer outcomes and customer understanding

At a glance...

Publication link	https://www.fca.org.uk/publications/good-and-poor-practice/digital-design-customers-online-journeys
Published date	31 July 2025
Who has published it?	FCA
Publication type	Guidance
What's it relevant to?	Financial services digital journeys

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at August 2025. Specific advice should be sought for specific cases. For more information see our terms & conditions.

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Date published

04 Aug 2025