Consumer Duty Marketing for Financial Services

Consumer Duty is the FCA’s framework for raising the standard of consumer protection across financial services. It came into force in July 2023 and sets out a clear expectation: firms must be able to demonstrate that their communications, products, and services deliver good outcomes for customers. Not just in theory. In practice, and with evidence to back it up.
For marketing and communications teams, that’s a significant shift. The FCA is no longer satisfied with disclosures buried in footnotes or terms and conditions that nobody reads. The standard is whether a real customer, in a real situation, can understand what you’re telling them — and whether your communications support them in making informed decisions.

Why Consumer Duty changes marketing standards

Before Consumer Duty, many financial services firms managed regulatory risk through disclosure. Add the right disclaimers, get the legal sign-off, move on. That approach no longer meets the bar.

The Duty requires firms to think about customer understanding, not just information provision. That means asking: does this person actually understand what we’re saying? Will this communication help them make a good decision? Can we demonstrate that with evidence?

The governance expectations have risen to match. Compliance teams are being asked to show not just what communications say, but how they were tested, what evidence was gathered, and how feedback shaped the final output. For marketing teams, that creates both a challenge and an opportunity to do better work.

What counts as a consumer communication?

Consumer Duty applies to any communication that a retail customer might encounter. In practice, that covers far more ground than most marketing teams initially assume:

• Website copy and landing pages
• Email campaigns and automated journeys
• Investor communications and fund materials
• Paid advertising across digital channels
• Product pages and descriptions
• Sales enablement content
• Customer onboarding journeys

If a retail customer sees it, the FCA expects it to meet the standard. That includes content produced by third parties on your behalf.

Compliance in financial services marketing has always been important. What’s changed is the scale of scrutiny, the speed of enforcement, and the direct link between regulatory failure and commercial damage.

The FCA has made clear it expects firms to have governance processes in place, not just good intentions. Marketing teams are being asked to evidence their approach to consumer understanding, and that evidence is being requested in formal reviews. For larger firms, this is already part of the board reporting cycle.

The commercial stakes are just as real. Non-compliant communications don’t just create regulatory risk. They create delays. A campaign that fails compliance review at the final stage can set a launch back by weeks or months, with costs that accumulate fast. And if a communication is found to be unclear, misleading, or unfair after publication, the remediation effort is far more expensive than getting it right the first time.

There’s also the reputational dimension. Trust is hard-won in financial services. A poorly judged communication, whether it oversimplifies a risk or makes a claim that can’t be substantiated, can do lasting damage to the relationship with customers who’ve taken years to acquire.

Common marketing risks financial brands miss

Most compliance failures in financial marketing don’t come from deliberate decisions. They come from habits and assumptions that were never properly tested. The issues we see most often:

• Unclear customer outcomes. Communications that describe product features without helping the customer understand what those features mean for them.
• Over-reliance on legal disclaimers. Using small print to qualify claims that the main copy makes too boldly.
• Complex language. Technical terminology that makes sense to the team who wrote it, but loses the people it’s aimed at.
• Benefits without balanced context. Leading with upside without giving customers the information they need to assess risk.
• Messaging inconsistency across channels. Different channels are making subtly different claims about the same product, creating confusion and potential compliance exposure.

FCA-compliant marketing means identifying and resolving these issues before campaigns go live — not after.

This is where Hub’s approach differs from most agencies.

Most agencies can write compliant copy. Fewer can tell you whether your audience actually understands it. Consumer Duty communications testing is the process of finding out — before your campaign launches — whether the people you’re trying to reach are receiving the message you intended.

We work with financial services firms to independently review and test customer-facing communications: assessing not just regulatory compliance, but genuine customer comprehension. Do audiences understand the key messages? Are they confident in what’s being asked of them? Is there anything in the communication that creates hesitation, confusion, or misinterpretation?

This kind of testing generates the evidence that regulators and compliance teams now expect. It also makes the communications better.

How communications testing works

Our testing process is structured to be both rigorous and practical. It doesn’t require months of research or extensive budgets, and it can be built into a campaign timeline without disrupting delivery.

1. Brief and objectives: We start by understanding what the communication is intended to achieve: who the audience is, what decisions they need to make, and what a good outcome looks like.
2. Audience assessment: We identify the right test participants — matching the profile of the people the communication will actually reach — and design the evaluation to reflect their level of financial knowledge and context.
3. Message evaluation: We expose test audiences to the communications and gather structured feedback on their understanding, confidence, and intent.
4. Clarity and comprehension analysis: We assess where the communication lands well and where it creates confusion, misinterpretation, or unnecessary friction.
5. Recommendations and revisions: We deliver clear, actionable recommendations for improving the communications — with a focus on changes that will pass both the compliance test and the customer understanding test.

What can investor communications testing reveal?

Testing investor communications regularly surfaces issues that internal review misses entirely — because the people reviewing internally already understand the product.

What we typically find:

• Misinterpretation risk: Language that the investment team reads as straightforward, but which investors interpret differently, sometimes materially so.
• Areas of confusion: Sections of copy that cause readers to pause, re-read, or disengage without understanding.
• Evidence of understanding: Where the communication is working well, and audiences are reaching the right conclusions with confidence.
• Confidence and decision quality: Whether the communication leaves investors feeling informed enough to act, or whether gaps in clarity undermine their decision readiness.

This is exactly the kind of evidence the FCA expects firms to hold. It’s also the kind of evidence that makes the next communication meaningfully better than the last.

Consumer Duty compliance review doesn’t have to be the last step before launch. In most firms, making it the last step is what creates the delays, the rework cycles, and the friction between marketing and compliance teams.

We work with financial services firms earlier in the process — reviewing content before it goes into formal approval, identifying the issues that are likely to be flagged, and recommending changes that make the compliance conversation faster and more straightforward.

The outcome is content that arrives at the approval stage in better shape. Fewer revisions. Fewer delays. A faster route from brief to publication.

Typical assets reviewed

Our pre-approval review service covers the full range of financial marketing content:

• Campaign creative and copy across all formats
• Website content and landing pages
• Product pages and fund descriptions
• Email journeys and automated communications
• Investor materials, presentations, and reports
• Sales enablement assets and adviser communications

We review against FCA requirements, Consumer Duty expectations, and where relevant, sector-specific guidance from bodies such as the AIC. Where there are issues, we explain them clearly and provide specific recommendations rather than generic observations.

Compliance-driven communication review is one part of what we do. The other is making the communications themselves genuinely better.

Regulatory requirements set the floor. The question we’re always asking is whether the copy is as clear, as compelling, and as useful as it can be within that floor — because compliant content and good content are not in conflict. They’re the same goal, approached from both directions.

Messaging optimisation for financial services covers:

• Plain English review: Identifying where technical language, passive constructions, or financial jargon are reducing clarity without adding anything meaningful.
• Message hierarchy: Ensuring the most important information is front and centre, not buried beneath context the audience didn’t ask for.
• Reducing ambiguity: Removing phrases or structures that could reasonably be interpreted in more than one way.
• Improving engagement within compliance constraints: Finding the creative space that exists within regulatory requirements and using it well.

Compliance and conversion are not opposites

This is worth stating clearly, because the assumption that they are holds a lot of financial services marketing back.

Clear communications outperform unclear ones. When customers understand what you’re offering and what it means for them, they’re more likely to engage, more likely to act, and more likely to stay. The FCA’s push for consumer understanding isn’t asking firms to make their marketing less effective. It’s asking them to make it more honest. And honest communication, delivered with clarity, builds the kind of trust that drives long-term customer value.

The financial services firms we see getting this right aren’t choosing between compliance and performance. They’ve stopped treating them as separate problems.

We’ve been working in financial services marketing for over 15 years. Not as a generalist agency that occasionally handles financial services for clients. As a specialist team that understands the regulatory environment, the investor mindset, and the creative challenge of making complex financial propositions genuinely engaging.

• Experience with regulated communications: We know what the FCA expects, how Consumer Duty applies in practice across different communication types, and where the real risks in financial marketing tend to sit. That experience means we can identify issues quickly and resolve them without a long education process on either side.
• A structured testing methodology: Our communications testing is not a read-through by a senior team member. It’s a structured process that generates real evidence of consumer understanding, built around the audiences who will actually receive the communication.
• Practical recommendations: We don’t flag problems without solving them. Every review comes with specific, actionable recommendations that a copywriter or designer can act on directly.
• Marketing and compliance alignment: We work to close the gap between marketing teams and compliance functions, not widen it. Bringing both teams into the process earlier, with clearer shared language, produces better outcomes on both sides of the relationship.
• A faster route from concept to approval: For many clients, the biggest gain from working with us isn’t a single piece of better content. It’s a communications process that’s more efficient from start to finish: fewer revisions, fewer delays, faster publication, and more confidence that what goes out is right.

Financial services marketing shouldn’t be a choice between being compliant and being effective. With the right process, clear methodology, and a team that understands both sides of that equation, you can reduce regulatory risk, improve the quality of every customer communication, and launch with confidence.

If you’d like to talk about how we can help with Consumer Duty communications testing, pre-approval review, or messaging optimisation, get in touch.