How to test Consumer Duty communications

To test a communication under the Consumer Duty, put it in front of people who look like the customers who will receive it and record what they understood, what they missed and who struggled. Dutified does this with a panel of AI-modelled customers built on your customer profile and the wider UK public, and reports the result across the four Consumer Duty outcomes.

The steps

  1. Choose the communication and the decision it supports. Pick the email, letter, web page, app screen, ad, statement or call script you want to test and write down what the customer has to understand or do after reading it.
  2. Describe the customers who will receive it. Use your customer profile to describe who reads the communication, and include the vulnerable groups set out in FCA guidance FG21/1 so that the readers who are most likely to struggle are included.
  3. Put the communication in front of a panel. Dutified has a panel of AI-modelled customers, built on your customer profile and the wider UK public, read the communication and respond to it.
  4. Read what they understood, what they missed and who struggled. The result is organised across the four Consumer Duty outcomes, so you can see which parts of the communication worked and which groups of customers found it hard.
  5. Change the communication and retest with the same panel. Edit the wording or layout and run the new version past the same panel, so that any difference in the result comes from your change.
  6. Keep the decision trail. Dutified records a full decision trail, which your teams can use in audit and in their own sign-off.

What to look for in the result

A useful result separates three things: what customers understood, what they missed and which groups of customers struggled. The last of these matters most for vulnerable customers, because an average can look healthy while one group finds the communication hard to follow.

No customer data is needed

No customer data ever enters Dutified. The panel is modelled on a customer profile and the wider UK public, so you can test a communication without sharing the data of the people you serve.

Where to look at the FCA

The consumer understanding outcome sits in PRIN 2A.5, and FG22/5 gives the FCA's guidance on the Consumer Duty, including how firms can test and monitor their communications. Read both for the exact wording.

Questions and answers

Do firms have to test communications under the Consumer Duty?

PRIN 2A.5.10R says that, where appropriate, a firm must test communications before communicating them to retail customers and regularly monitor their impact afterwards. PRIN 2A.5.12G lists the factors that decide when a test is appropriate, and the judgement on each communication stays with the firm.

Which communications should we test first?

Start with the communications that prompt a decision, reach many customers, are likely to reach customers in vulnerable circumstances or could cause harm if misunderstood. Those are the factors PRIN 2A.5.12G asks firms to weigh.

How do I retest a letter to prove the new version works better?

Test the new version on the same panel that read the old one, so that any difference in the result comes from your change. Dutified keeps the panel the same between runs for this reason.

Can we test communications without using real customer data?

Yes. No customer data ever enters Dutified, because its panel is modelled on a customer profile and the wider UK public.

Related guides

Dutified gives feedback and does not give legal or compliance advice. It reports how modelled readers responded, and every decision stays with your firm.

To test your own communications with Dutified, join the waitlist or read how it works.