On 27 July, the FCA published a blog titled "Outcomes monitoring: why understanding the consumer experience matters and where firms should focus." It does not introduce a new regulatory expectation, nor does it change Consumer Duty. Instead, it reinforces an important message: firms should not simply collect data about customer interactions. They should understand what those interactions tell them about customer outcomes and use that insight to drive improvement.
Taken alongside the recently published Mills Review, it also raises a much bigger question for the industry.
As financial journeys become increasingly personalised through AI, how will firms continue to evidence that consumers genuinely understood the information they received?
When Consumer Duty was introduced, the FCA made it clear that firms should communicate in ways that support consumers in making effective, timely and properly informed decisions.
That expectation has never been about producing clearer documents for the sake of it. It has always been about whether communications actually help consumers understand complex information well enough to make informed decisions.
The Consumer Understanding outcome requires firms to test communications, monitor how consumers respond and make improvements where necessary.
In other words, Consumer Duty has always been about understanding. The challenge has always been evidencing it.
Many firms have invested considerable time improving the quality of their customer communications. Language has become simpler. Documents have become shorter. Digital journeys have become more intuitive.
Yet many of the measures organisations continue to rely on remain largely activity-based.
Was the email delivered? Was the document opened? Did the customer visit the webpage? Did they complete the journey?
These are useful operational measures. But they do not necessarily answer the question that really matters.
Did the customer understand the information well enough to make an informed decision?
An email being opened does not demonstrate understanding. A document being downloaded does not prove comprehension. Even completing a digital journey does not necessarily show that the customer appreciated the implications of the decision they were making.
Engagement should never be confused with understanding.
Charlotte Clark, the FCA's Director of Cross-cutting Policy and Strategy, makes a simple but important point in the latest publication. Understanding customer outcomes is "about more than collecting data or producing reports."
The strongest firms do not simply produce management information. They use it to identify where customers may be struggling, understand why, make improvements and assess whether those improvements actually led to better outcomes.
That is a subtle but significant distinction. The value of monitoring is not the volume of data collected. It is what firms learn from it.
The FCA describes organisations that do not simply report what they monitored. They demonstrate what happened as a result.
For firms communicating complex financial information, consumer understanding should form an important part of that evidence.
Questions worth asking include: which topics consistently confuse customers? Which explanations require repeated viewing? Where do customers abandon a journey? Which customer groups appear to struggle most? Do customers understand the key information needed to make an informed decision? Do changes to communications actually improve understanding?
These are not simply communications questions. They are customer outcomes questions. Because if a communication exists to support better decisions, firms should have some way of assessing whether it achieved that objective.
This is where the FCA's latest publication becomes particularly interesting when considered alongside the Mills Review.
The Review rightly highlights the enormous opportunity AI presents for financial services. Consumers can receive communications that are more relevant, more timely and more personalised than ever before. That has the potential to transform customer engagement.
But it also creates a new challenge.
Historically, firms could test a relatively small number of standard communications. Tomorrow's customer journeys are unlikely to be standard. Increasingly, consumers may receive different explanations, different prompts, different educational content and different recommendations based on their own circumstances. That is exactly what personalisation is intended to achieve.
However, it also means firms may need to evidence consumer understanding across thousands, or potentially millions, of unique customer journeys rather than a handful of standard communications.
In my view, that makes evidencing consumer understanding significantly harder. Not less important.
Traditional communication metrics become increasingly limited in this environment. Knowing that a personalised communication was opened tells us very little about whether the customer understood it. Knowing that someone completed an AI-driven journey tells us little about whether they appreciated the consequences of the decisions they made.
As personalisation increases, the need to evidence consumer understanding is likely to increase with it.
None of this means every firm requires sophisticated technology or complex measurement frameworks. The FCA is clear that firms should adopt approaches proportionate to their size, products, customers and the potential risk of harm.
A small advice firm will naturally monitor outcomes differently from a major retail bank. But proportionality should not become an excuse for relying solely on activity metrics.
Every firm should be able to answer a simple question: what evidence gives us confidence that our customers genuinely understood the information we provided?
The answer will vary between organisations. The question should not.
The FCA also places considerable emphasis on governance. Boards should receive more than dashboards showing open rates, completion statistics or management information. They should understand what issues were identified, why those issues occurred, what actions were taken, and whether those actions resulted in better customer outcomes.
Ultimately, the purpose of outcomes monitoring is continuous improvement. Not simply compliance reporting.
Consumer Duty has not changed. The FCA's latest publication simply reinforces what was always expected.
The challenge facing firms today is not understanding the regulation. It is demonstrating, in a practical and proportionate way, that customers genuinely understand increasingly complex financial information.
The Mills Review suggests AI will make financial journeys more personalised over the coming years. That makes evidencing consumer understanding more important than ever.
Ultimately, Consumer Duty was never about sending more information. It was about helping consumers make effective, timely and properly informed decisions.
The FCA's latest publication is a timely reminder that firms should not simply evidence what they communicated. They should be able to show what they monitored, what they learned, what they improved and, most importantly, what happened as a result.
At FCX Technologies, we have been researching the gap between delivering a financial communication and evidencing that it was understood for several years. That research directly shaped the design of Video Canvas.
In a structured study comparing four communication formats, participants who received information through a Video Canvas experience answered 95% of knowledge questions correctly after a single viewing. Those receiving the same information on paper answered 68% correctly. The study found a 44% increase in understanding when Video Canvas was used, and 30% fewer misunderstandings compared to paper.
The recap game built into every Video Canvas experience goes further. It invites the viewer to confirm their understanding through a short drag-and-drop exercise, and captures individual-level evidence of comprehension. That evidence lives entirely within the licensing organisation's own infrastructure. FCX Technologies does not hold or process it.
As the FCA's publication makes clear, the question firms need to answer is not whether a communication was sent. It is whether it worked. For firms thinking seriously about how to evidence consumer understanding as personalisation increases, that is a question Video Canvas was built to help answer.
If you would like to discuss how Video Canvas from FCX Technologies could support your outcomes monitoring approach, we would welcome the conversation.
Contact the team at fcxtechnologies.com/contact.
"Great video content is so engaging for members, especially when it is deeply personalised to them. We chose to partner with Video Canvas, not just for great tech, but for their creativity and their strong focus on security."
Chris Connelly
Chief Strategy Officer
