Customer understanding testing and the FCA

Customer understanding testing is a structured check that the people who receive a communication understand it well enough to make good decisions, which is the aim of the consumer understanding outcome in PRIN 2A.5 of the FCA Handbook. Dutified is one way to run that check, using a panel of AI-modelled customers that reports what customers understood, what they missed and who struggled.

What the check measures

The check measures understanding of the communication itself, so it asks whether customers took away the points the firm needed them to take away. A good test also shows which groups of customers differed, because understanding varies with age, circumstances, confidence and ability to engage with financial products.

How it connects to the four Consumer Duty outcomes

The four outcomes are products and services, price and value, consumer understanding and consumer support. Dutified reports results across all four, because a single communication can affect how well a customer understands what they are buying, how its price and value are explained and how to get help.

How Dutified runs it

Dutified has a panel of AI-modelled customers, built on your customer profile and the wider UK public and including the vulnerable groups in FG21/1, read and respond to the communication. The report shows what they understood, what they missed and who struggled, with a full decision trail, and you can retest with the same panel after a change.

Where to look at the FCA

PRIN 2A.5 sets out the consumer understanding outcome and FG22/5 explains the FCA's thinking on it, so read both to see what the FCA says about communications and about how firms can check that customers understand them.

• PRIN 2A.5, the consumer understanding outcome
• Consumer understanding: good practice and areas for improvement (FCA)
• FG22/5, FCA guidance on the Consumer Duty
• FCA Consumer Duty overview

Questions and answers

What does the FCA say about customer understanding testing?

The consumer understanding outcome is in PRIN 2A.5, and PRIN 2A.5.10R says that, where appropriate, a firm must test communications before they reach retail customers. The FCA has also published a page on consumer understanding good practice and areas for improvement, linked below.

What is the difference between comprehension testing and a readability score?

A readability score describes how complex the wording is. Comprehension testing records what readers took away from the communication and which groups missed the point, so it answers the question the consumer understanding outcome asks.

Is there a tool for Consumer Duty comprehension testing?

Several approaches exist, from research agencies that recruit customers to AI-modelled customer panels. Dutified is an AI-modelled panel that reports what customers understood, what they missed and who struggled across the four Consumer Duty outcomes.

Related guides

• The consumer understanding outcome explained
• How to test Consumer Duty communications
• Alternatives to customer panels for testing communications

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.