On 31 July 2025, the Financial Conduct Authority (FCA) published findings of its review of consumer credit customers’ online journeys. The increasing use of technology has affected how customers engage with firms, apply for products and borrow money. The purpose of the FCA’s research is to understand how firms acquire customers through digital channels and ensure that they are delivering good customer outcomes, in line with the Consumer Duty.

The review identified that the design of digital platforms can encourage customers in a specific direction and influence their understanding of products and features. As such, design can support good consumer outcomes. However, customers may also be driven towards quick decisions which may not be in their best interests or consistent with the Consumer Duty.

The review focused on specific categories such as design aspects, different customer groups, testing and quality assurance, and management information and oversight. Below we discuss some of the key findings and considerations for firms to improve their online customer journeys.

Firms often neglect target customer needs, fail to support vulnerable individuals, and make it hard to disclose vulnerabilities. Poor design can lead to rushed decisions, biased nudges, and unclear product information. Marketing focused on speed may mislead customers and harm outcomes. Key product details, such as fees and features, are sometimes not clearly presented, limiting customer understanding and informed decision-making.

Firms should design digital journeys to meet diverse customer needs, support vulnerable groups, and use clear layouts with plain English. Add friction if helpful, include visuals, involve frontline agents, and ensure testing for good outcomes, focusing on speed and timely information.

Firms should better tailor digital journeys to the needs of their target customers, including offering alternative communication channels and additional support. They should analyse target markets to understand customer needs, including those acquired through various channels, requiring extra support, or with vulnerabilities. Digital-only firms must ensure support for non-standard issues and vulnerable customers, offering additional help for third-party referrals. Identifying vulnerable customers and testing support channels improves effectiveness.

Firms should test product information for clarity, ensuring fees and features are understood. Accessibility software simplifies language but may not aid comprehension of complex products. Therefore, firms must test language used in their website, apps and promotion and assess how easy it is to understand.

Testing should cover end-to-end journeys, device compatibility, and visibility of pages and settings. Firms should ensure that quality assurance, data and feedback is used to improve support and the digital journey. Quick digital journeys may lack necessary friction, and testing should ensure all customer groups achieve good outcomes.

Relying too heavily on online reviews, will rarely provide a full picture of customer outcomes. Data showing customers rushing through journeys without accessing key information or support should be analysed to improve design and outcomes.

It is expected that the benefits arising from these technologies will continue to grow over the next three years. As the perceived benefits grow, so do the perceived risks. It is vital that firms consider the relevant risks and take into account the best practice guidance published by the regulator to improve their systems and processes and to ensure that they do not fall short of the Consumer Duty requirements and other relevant regulations.