Consumer Duty and website content: evidencing consumer understanding

The Consumer Duty asks firms to evidence outcomes rather than to tick off disclosures. For digital teams that shift is significant: the question is no longer only "did we say it?" but "was it likely to be understood, and can we show that?"

This guide focuses on the two outcomes that touch website content most directly.

Consumer understanding

Practical checks that map to this outcome:

• Prominence matches importance. If a limit or exclusion would surprise a reasonable customer, it should not appear only in a linked PDF.
• Consistency across surfaces. The product page, the quote summary, the confirmation email and the IPID should describe cover the same way.
• Plain language. Sentence length, defined terms and unexplained insurance vocabulary are all measurable, and readability is a reasonable proxy for comprehension.
• Price presentation. Fees introduced after a headline price is quoted are one of the most common findings we see on insurance journeys.
• Testing evidence. Where wording has been changed for clarity, keeping the before and after, and the reason, is often the most useful record.

Consumer support

Support outcomes show up on a website in the routes it offers:

• Can an existing customer find how to make a claim without signing in?
• Is cancelling or amending a policy as easy to find as buying one?
• Are contact routes for vulnerable customers described?
• Do self-service journeys have a fallback when they fail?

Asymmetry between buying and leaving is worth measuring: count the clicks to buy, then the clicks to cancel.

Renewals

Renewal communications are a recurring source of findings because they are generated by systems that are updated less often than the website. Check that the presentation of last year's premium, any change in cover, and the options available are consistent with what the website says.

Building the evidence trail

The Duty rewards a record of review. Scheduled scans produce that record as a by-product: each run is timestamped, each finding has an owner and a status, and score changes over time show whether the content is improving.

Observe IQ is a compliance-support tool. Results should be reviewed by an appropriately qualified person. Observe IQ does not provide legal advice or guarantee regulatory compliance.