Consumer Duty 2026: What Financial Marketers Need to Know

Consumer Duty in 2026: Where Financial Marketing Stands Today

The implementation deadline has passed. The announcements have been made, the internal frameworks have been built, and most financial services firms have at least a working compliance structure in place. But Consumer Duty has not settled into the background. If anything, the expectations on marketing teams are higher now than they were at launch.

We’re now in the maturity phase. The FCA is no longer asking whether firms have a Consumer Duty policy. It’s asking whether firms can demonstrate that their communications are actually working for customers — whether they’re generating the right outcomes, and whether the evidence exists to prove it.

That shift is significant for marketing teams. Communications are no longer just a campaign function. They sit within compliance governance, which means marketing decisions now carry accountability in a way they didn’t before. What’s being published, who approved it, how it was tested, and what the outcomes were — these are questions that regulators, boards, and compliance teams are increasingly expecting marketing to answer.

The firms doing this well aren’t treating Consumer Duty as an annual review. They’ve built it into the way they brief, write, approve, and evaluate communications on an ongoing basis. The firms finding it harder are still treating compliance as the last step before launch, rather than a thread running through the whole process.

2026 is the year that the gap becomes commercially visible.

A Plain English Refresher: What Consumer Duty Actually Requires

Consumer Duty sets out four outcomes the FCA expects firms to deliver for retail customers. For marketing teams, these are not abstract principles. They translate directly into decisions about what to say, how to say it, and what evidence to hold.

• Good outcomes for customers: Your communications should leave customers better placed to make decisions that serve their interests — not confused, misled, or pushed towards products that aren’t right for them.
• Support for informed decision-making: Information should be presented in a way that helps customers understand what they’re being offered, what it costs, what the risks are, and what alternatives exist.
• Communications that are understandable and actionable: The FCA’s standard is not whether a communication is technically accurate. It’s whether a real customer, reading it in a normal context, would understand it and know what to do next.
• Reducing foreseeable harm: If a communication could reasonably mislead a customer, create confusion about a material point, or obscure relevant risk information, that’s a Consumer Duty issue — regardless of whether there was any intention to mislead.

Why marketing teams are directly impacted

Consumer Duty applies wherever a retail customer might encounter a communication from your firm. For marketing teams, that means the scope is broad:

• Website copy and landing pages
• Campaign messaging across paid and organic channels
• Product pages and service descriptions
• Email communications and automated nurture journeys
• Investor communications and fund materials
• End-to-end customer journeys from first touch through to onboarding

Every one of these touchpoints now carries compliance weight. And every one of them needs to meet the standard for consumer understanding, not just legal accuracy.

The Biggest Consumer Duty Risks for Financial Marketers in 2026

Most compliance failures in financial marketing are not the result of deliberate decisions. They’re the result of habits and assumptions that were never tested against real customer understanding. These are the patterns we see most consistently.

Complex messaging that customers misunderstand

Financial services products are genuinely complex. Investment strategies, risk parameters, fee structures, platform mechanics — there’s a lot to explain, and the people who know the product best are usually the ones writing the copy.

That creates a persistent problem. Language that makes sense to an internal team can land completely differently with a customer who has no prior context. Technical terms get used without definition. Product explanations assume knowledge that most retail customers don’t have. Key conditions get buried in qualifications rather than stated plainly upfront.

The FCA’s standard is customer understanding, not technical accuracy. A communication can be entirely correct and still fail Consumer Duty if the audience can’t interpret it as intended.

Approval processes that prioritise sign-off over understanding

The compliance approval process exists for good reasons. But in many firms, it has evolved into a legal and technical review that checks whether claims are accurate and properly caveated — without ever assessing whether customers would actually understand them.

Sign-off from a compliance officer or legal team is not evidence of customer understanding. It’s evidence that the communication met an internal review standard. Those are different things, and the FCA is increasingly clear about the distinction.

Firms that can only point to internal approval when asked how they evidenced customer understanding are carrying more risk than they realise. The expectation is that firms go further: testing communications with representative audiences and using that evidence to improve the messaging before it goes out.

Campaign performance metrics that ignore consumer outcomes

Marketing dashboards are built around campaign performance: impressions, clicks, open rates, conversion. These are useful measures, but they don’t tell you anything about whether customers understood the communications that drove them to act.

A high click-through rate on a poorly understood message is not a Consumer Duty success. Customers taking action based on a misinterpretation of what a product does is precisely the kind of foreseeable harm the regulation exists to prevent.

In 2026, the more useful question is not whether customers clicked. It’s whether they understood what they were clicking towards, whether they felt confident in the decision, and whether the outcome of that decision served their interests. Those are harder metrics to capture, but they’re the ones that will matter when the FCA comes asking.

What FCA-Compliant Marketing Looks Like in Practice

Compliant marketing is not cautious marketing. It’s clear marketing. The distinction matters because the common response to compliance pressure — hedging claims, adding more disclaimers, softening language until everything is technically defensible but practically useless — tends to make communications worse for customers, not better.

FCA-compliant marketing in practice means:

• Audience-first messaging: Start with what the customer needs to know and how they’ll receive the information, not with what the product team wants to communicate. The two are often different.
• Clear customer outcomes: Every communication should make it easy for a customer to understand what they’re being offered, what it will cost them, what the risk profile is, and what a good or bad outcome might look like.
• Balanced presentation of benefits and risks: Benefits and risks should be presented with equivalent prominence and clarity. Risk information in footnote type after four paragraphs of headline benefits is not balanced — and the FCA has been explicit about this.
• Consistency across channels: The same product, described differently across your website, your email campaigns, and your paid advertising, creates confusion and potential compliance exposure. Consumer Duty applies to the totality of what a customer encounters, not individual pieces reviewed in isolation.

Questions marketing teams should ask before publishing

Building a short internal review habit doesn’t require a new process. It requires adding a few questions to the one you already have:

• Would a customer with no prior product knowledge interpret this as we intend?
• Are the decisions they need to make clear and easy to act on?
• Is the information they need to make a good decision visible, or buried?
• If the FCA asked us why we believe customers understand this, what would we say?
• Can we demonstrate that the messaging works for real audiences, not just internal reviewers?

If those questions don’t have clear answers before a communication is published, the risk lies in your approval pipeline rather than in your campaign performance data.

Why Communications Testing Is Becoming a Competitive Advantage

Testing communications before launch used to be seen as a nice-to-have — useful for major campaigns, optional for everything else. Consumer Duty has changed that calculus.

Firms that test now have something their competitors don’t: evidence. Evidence of customer understanding, evidence of message clarity, evidence that the communications they’re publishing are working as intended. That evidence satisfies regulatory expectations, strengthens internal approval processes, and makes every subsequent round of content better by building on what real audiences actually understood.

The firms investing in communications testing are also finding that it reduces remediation costs significantly. Catching a misinterpretation issue before launch is a relatively small fix. Catching it after a campaign has run — or in an FCA review — is an expensive, time-consuming, and reputationally damaging problem.

What Consumer Duty communications testing measures

Effective communications testing is not a read-through by a senior team member. It’s a structured process that assesses:

• Clarity: Is the language accessible to the intended audience?
• Understanding: Do customers take the meaning the communication intends?
• Confidence: Does the communication leave customers feeling adequately informed?
• Decision readiness: Are customers clear on what they’re being asked to do and why?
• Message interpretation: Where does the communication land well, and where does it create confusion or hesitation?

The output is not a pass/fail. It’s actionable intelligence that makes the communication better and provides the evidence trail that Consumer Duty governance requires.

Investor communications testing: a growing priority

The complexity of investor communications makes testing particularly valuable in this space. Investment products — funds, trusts, structured products, platforms — carry inherent complexity, and the gap between how an investment team describes a strategy and how a retail investor receives that description can be substantial.

High-value financial decisions deserve communications that have been genuinely tested for customer understanding. And as Consumer Duty expectations extend further into the investor communications space, firms that have established testing processes are in a significantly stronger position than those that haven’t.

A Practical Consumer Duty Checklist for Marketing Teams

Messaging

• Review all customer-facing copy for plain English. Remove technical terminology or define it clearly in context.
• Check that benefits and risks are presented with equivalent prominence across all formats.
• Confirm that the target audience can understand the communication without prior product knowledge.
• Review messaging consistency across all channels carrying the same product or campaign.

Governance

• Document the approval workflow for each communication type and confirm it includes customer understanding assessment, not just legal sign-off.
• Establish a process for capturing evidence of customer understanding, whether through formal testing, customer research, or structured feedback.
• Maintain clear records of review decisions, including what was changed and why. The FCA expects firms to be able to reconstruct this history.

Validation

• Test significant communications with representative audience samples before launch, particularly for new products, complex propositions, or high-volume campaigns.
• Build a systematic process for capturing customer feedback on communications after publication and feeding that into future briefs.
• Review communications performance data not just for campaign metrics but for signals of customer confusion: high bounce rates from product pages, low completion on customer journeys, high volumes of follow-up queries on points the communication should have resolved.

Case Study

• How The Merchants Trust Reassured Investors with Human‑Centric Campaigns

Preparing for the Next Stage of Consumer Duty

Consumer Duty is not a project with a finish line. It’s an operating model, and the expectations around it will continue to evolve as the FCA reviews how firms are performing and where the ongoing risks in retail financial services communications are sitting.

The marketing teams that are best placed for whatever comes next are the ones who have already stopped treating compliance as a gate at the end of the process. They’ve built customer understanding into how they brief work, how they test it, and how they evaluate it after launch. They have evidence to show regulators, boards, and clients that their communications are working for the people receiving them.

That shift in approach doesn’t just reduce regulatory risk. It produces better communication. Clearer messaging, better-informed customers, more confident decisions, and stronger long-term relationships. The commercial and regulatory cases for doing this properly are pointing in the same direction.

If you’d like to talk about how Hub can support your Consumer Duty communications programme — whether that’s testing, pre-approval review, or messaging optimisation — get in touch with our team.