With the arrival of the FCA’s Consumer Duty, firms now have to prove that their communications are understood by their customers.

This means firms need to gather the right evidence to prove that their communications make sense and are supporting customers to make good decisions.

Our Clear and Simple Mark

Achieving our Clear and Simple Mark is one way of evidencing that your communications are written in clear language and designed in a way that helps customers to understand what they’re reading.

With a decade of experience rewriting, redesigning, and testing communications, we have a clear understanding of what good looks like. Our clear and simple criteria are based on extensive research around what makes documents easiest to understand. Our mark set a high bar in terms of both clear language and design.

Many of Britain’s largest and most respected financial services firms now carry our Clear & Simple Mark endorsement on their literature. And Fairer Finance’s work on readability is referenced in the FCA’s Consumer Duty Finalised Guidance (para 8.35).

Testing communications on customers

The FCA has made it clear that it expects firms to use customer testing, where appropriate and proportionate, as an additional means of proving that their documents are understood.

We believe firms should prioritise the testing of documents that are more likely (if poorly written or designed) to lead to greater consumer harm. This means considering the number of customers affected and the magnitude of the possible harm to each customer. Firms should also consider whether there is a risk of harm to more vulnerable customer segments.

Different approaches to testing will be appropriate for different providers and communications. There are trade-offs in terms of qualitative insights versus quantitative data, and the choice of the sample and the sample size will have implications for your timelines and budget.

It is important to design the testing carefully, such that the results are robust and free from confounding factors such as selection bias and spillover effects. The best approach for you will depend on whether you require in-depth qualitative reactions from a specific set of customers, or quantitative data on how a large sample of customers responded to the communication.

Banks, insurers, and other providers have asked our team to design and deliver a range of testing approaches, including qualitative and quantitative approaches.

A|B tests

Customer testing is most effective when carried out on real customers in a live environment. This is easiest to do in online environments. But where firms have the capability, we also support them in using A|B testing to assess the effectiveness of emails, letters and SMS messages. These tests monitor how customer behaviour changes as different designs and language are used in key communications. It some cases it is advisable to first test the effect of a communication on customer behaviour in a ‘hypothetical’ setting (online behavioural experiments).

Online surveys

We design online comprehension tests for letters, emails, and other communications. This is presented to a nationally representative sample of participants of an online polling panel. Participants are asked to read the communication and then answer a set of multiple-choice questions around the intended key messages. Online surveys allow firms to access a large sample of participants, but the feedback is less detailed than focus groups.

Focus groups

We recruit a nationally representative group of participants or people with various vulnerable characteristics to take part in our qualitative research projects. Participants are presented with samples of client literature, and asked questions to determine their comprehension of the key messages. The number of participants is smaller in focus groups – but the feedback is richer and more detailed.


Whichever approach to testing we use, where we can we will benchmark your communications against the anonymised results of other providers for similar communications. This will give you a sense of how your documents performed relative to other comparable communications.

If you would like to discuss your approach to testing, please contact us through the details below.

Contact us

With the introduction of the Consumer Duty regulation, we approached Fairer Finance to test our communications to ensure consumer understanding was at the highest standard possible. Oliver and the research team were extremely helpful from start to finish, giving us detailed and actionable feedback. We would fully recommend them to anyone looking to achieve the same result.

John Armstrong, Commercial and Marketing Director, Hastings Direct