Consumer Duty UX evidence
Consumer Duty UX Evidence Built for Asset Managers
The FCA expects firms to demonstrate good outcomes for retail customers. OpenScouter gives asset managers behavioural evidence from real users, captured across three data streams, so your Consumer Duty submissions are grounded in observed behaviour, not assumption.
Consumer Duty Raises the Bar on Evidence
The FCA's Consumer Duty, introduced through PS22/9 in 2022, shifted the regulatory standard from process compliance to outcome delivery. Asset managers serving retail investors must now show that their products, communications, and digital journeys genuinely support customer understanding and informed decision-making.
For asset managers, the digital touchpoints under scrutiny include fund selection flows, risk-warning disclosures, charges and costs pages, and investor portal onboarding. These are not abstract compliance concerns. They are the exact screens where confused or frustrated users abandon journeys, make uninformed choices, or disengage entirely.
Standard analytics tell you where users drop off. They do not tell you why. Without behavioural evidence, your Consumer Duty documentation rests on internal assumptions about what retail customers understand. The FCA has been explicit that firms must demonstrate outcomes, not intentions.
Firms must act to deliver good outcomes for retail customers across products, price and value, consumer understanding, and consumer support
For asset managers, this FCA requirement lands directly on digital product design. Retail investors navigating fund selection tools, charges disclosures, and risk-warning pages must genuinely understand what they are reading and be supported through the journey. Demonstrating that outcome requires more than internal review or standard analytics. Behavioural research, conducted with real users and producing timestamped evidence of comprehension and friction, is the method that connects observed customer experience to the outcome categories the FCA has defined. Asset managers who can point to structured behavioural evidence are in a materially stronger position when the FCA asks how they know their digital journeys deliver good outcomes.
Our approach
Behavioural Sessions on Your Actual Journeys
We run remote testing sessions with neurodivergent participants navigating your real fund selection pages, risk-warning disclosures, and charges summaries. Neurodivergent testers surface comprehension failures and friction points that neurotypical users overlook, giving you a higher-signal evidence base for Consumer Duty purposes.
Three Data Streams Correlated by AI
Every session captures interaction signals, think-aloud voice, and facial expression in parallel. The AI pipeline correlates the three streams to identify moments where a participant's verbal confusion, hesitation behaviour, and emotional response all converge. Human researchers confirm every finding before it reaches your report.
Reports Structured for Regulatory Use
OpenScouter reports are written to be read by compliance and legal teams, not just designers. Findings are mapped to the Consumer Duty outcome categories where relevant, and each issue is supported by timestamped behavioural evidence. Our reports are evidence, not legal opinion, but they are built to sit inside a regulatory submission.
What you receive
- Behavioural research report covering identified usability and comprehension issues across tested journeys
- Timestamped session recordings with annotated interaction, voice, and facial expression data
- Issue log mapped to Consumer Duty outcome categories including consumer understanding and consumer support
- Prioritised recommendations for design and content teams, ready to act on without further interpretation
- Executive summary suitable for inclusion in Consumer Duty board reporting or FCA evidence packs
Frequently asked
- Which parts of our digital estate should we test first for Consumer Duty purposes?
- Fund selection flows, risk-warning and charges disclosure pages, and investor portal onboarding are the highest-priority areas for most asset managers. These are the journeys where comprehension failures have the clearest link to poor customer outcomes under the Consumer Duty framework.
- Why use neurodivergent testers for a regulatory evidence exercise?
- Neurodivergent participants, including people with ADHD, dyslexia, and autism, find comprehension and usability issues that neurotypical users do not surface. For Consumer Duty purposes, this matters because the FCA's consumer understanding outcome applies to your full retail customer base, not only the most digitally confident segment.
- How does OpenScouter fit alongside our existing compliance and UX processes?
- OpenScouter is a complement to your in-house design team and existing tools. We provide the behavioural evidence layer. Your compliance team interprets that evidence in the context of your regulatory obligations. We do not replace legal counsel or internal compliance review.
- How long does a typical engagement take?
- Most engagements move from study brief to delivered report within a matter of days. Timelines depend on the number of journeys tested and the complexity of the brief. We can discuss a realistic schedule during an initial scoping call.
- Are the reports suitable for submission to the FCA directly?
- Our reports are structured to be readable by compliance and legal teams and to sit inside a regulatory evidence pack. They are not legal opinions and should be reviewed by your compliance function before any regulatory submission. The behavioural evidence they contain is timestamped and sourced from observed sessions.
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Talk to a behavioural researcher
Tell us about the vertical, the journey, and the evidence you need. We will scope a pilot in days, not weeks.