Consumer Duty UX evidence
Consumer Duty UX Evidence for BNPL Lenders
The FCA expects BNPL firms to demonstrate fair value, genuine understanding, and adequate support before formal regulation arrives. Behavioural research gives you the documented evidence that your checkout flows, repayment disclosures, and affordability prompts actually work for real users.
BNPL Lenders Face a Compliance Gap That UX Data Can Close
The FCA has made clear that BNPL firms are expected to meet standards comparable to regulated lenders right now, not after legislation passes. That means your product teams cannot wait for a formal Consumer Duty PS22/9 extension before gathering evidence that customers genuinely understand the credit terms they are accepting at checkout.
The problem is that standard analytics tell you what users do, not whether they understood what they agreed to. A customer who clicks through a repayment schedule disclosure is not the same as a customer who comprehended it. Regulators and auditors increasingly want evidence of the latter, and session recordings alone do not provide it.
BNPL journeys compress credit decisions into seconds. The affordability question, the instalment breakdown, the late payment warning: these appear and disappear faster than most users can process them. Identifying exactly where comprehension breaks down requires observing real users in real time, capturing what they say, where they hesitate, and what their expressions signal before they tap confirm.
BNPL agreements are currently unregulated, but firms must still apply fair-value, understanding and support standards comparable to regulated lenders ahead of formal regulation
For BNPL lenders, the FCA's position means the compliance clock is already running. Firms cannot treat the absence of formal legislation as permission to defer evidence-gathering. The expectation of fair-value, understanding, and support standards right now creates an immediate need for documented proof that your checkout and disclosure flows work as intended for real users, including those who process information differently. Behavioural research is the most direct way to generate that proof, because it captures what users actually understood, not just what they clicked.
Our approach
Three-Stream Capture Across the Checkout Flow
OpenScouter records interaction signals, think-aloud voice, and locally processed facial expression simultaneously. For BNPL lenders, we map these streams against the specific moments that matter to the FCA: the point of credit agreement, the instalment disclosure screen, and the affordability confirmation step.
Neurodivergent Participants as a Higher-Signal Panel
Our panel includes participants with ADHD, dyslexia, autism, and other cognitive differences. These testers surface comprehension failures that neurotypical users overlook. In a BNPL context, that means catching confusing instalment language, ambiguous late-fee disclosures, and checkout layouts that obscure the total cost of credit before a broader population encounters them.
Human-Confirmed Reports Built for Evidence Purposes
Every insight is reviewed by a human researcher before delivery. Reports are structured so that compliance, legal, and product teams can all use them. They document observed behaviour, not inferred intent, which is the kind of evidence that supports a Consumer Duty fair-value assessment or a regulatory audit response.
What you receive
- Annotated session recordings mapped to BNPL checkout journey stages, including credit agreement, instalment disclosure, and affordability confirmation
- Behavioural insight report correlating voice, interaction, and facial expression data across all three streams
- Participant comprehension summary covering the clarity of repayment terms, late payment warnings, and total cost of credit disclosures
- Prioritised issue log with severity ratings, suitable for handoff to product and design teams
- Evidence pack formatted for use in Consumer Duty fair-value assessments or FCA supervisory requests
Frequently asked
- Does OpenScouter provide legal or regulatory advice?
- No. Our reports are behavioural evidence, not legal opinion. They document what real users did, said, and expressed during your BNPL checkout flow. How that evidence is used in a regulatory submission is a matter for your legal and compliance teams.
- Which parts of the BNPL journey do you test?
- We focus on the stages where comprehension is most consequential: the point of credit agreement, the instalment breakdown screen, affordability prompts, and late payment disclosures. We can also test post-purchase account management flows if repayment support is a concern.
- How are facial expression and voice data handled?
- Facial expression analysis runs on-device using computer vision. No raw facial data leaves the participant's machine. Voice recordings are processed in line with our data handling policy. All participants provide informed consent before any session begins.
- How long does a study take from brief to report?
- Most engagements move from study brief to delivered report within days, not months. The exact timeline depends on participant recruitment requirements and the number of journey stages in scope. We will confirm a realistic schedule before work begins.
- Is OpenScouter a replacement for our existing research tools?
- No. OpenScouter is a complement to tools like Hotjar, UserTesting, Maze, and Dovetail. We add a specific capability: simultaneous three-stream behavioural capture with a neurodivergent panel, producing human-confirmed reports. Your existing analytics and research infrastructure continues to do what it already does well.
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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.