Consumer Duty UX evidence
Consumer Duty UX Evidence for Motor Insurance
The FCA expects motor insurers to demonstrate good customer outcomes, not just assert them. OpenScouter runs behavioural research sessions with neurodivergent participants and delivers structured evidence your compliance and design teams can act on together.
Motor Insurers Face a Specific Evidential Gap Under Consumer Duty
The FCA's Consumer Duty, introduced through Policy Statement PS22/9 in 2022, requires firms to show that their products, pricing, and digital journeys genuinely serve retail customers well. For motor insurers, that obligation extends to every stage of the online experience: quote generation, policy comparison, add-on presentation, and renewal flows. Asserting that a journey is clear is not sufficient. Evidence is required.
The challenge is that standard analytics tell you where customers drop off, not why. A customer who abandons a motor insurance quote mid-flow may have encountered confusing excess wording, an overwhelming add-on screen, or a renewal price presented in a way that obscures the year-on-year change. Clickstream data alone cannot distinguish between these causes.
Neurodivergent users, people with ADHD, dyslexia, autism, and related cognitive differences, surface these friction points faster and more visibly than neurotypical users. Their think-aloud commentary, combined with interaction signals and facial expression data, produces the kind of behavioural evidence that supports a Consumer Duty compliance narrative grounded in real customer experience.
Firms must act to deliver good outcomes for retail customers across products, price and value, consumer understanding, and consumer support
For motor insurers, the Consumer Duty obligation is not abstract. The FCA's four-outcome framework, covering products and services, price and value, consumer understanding, and consumer support, maps directly onto the digital journeys where customers make consequential decisions: choosing cover levels, accepting or declining add-ons, and responding to renewal pricing. The consumer understanding outcome is particularly pointed for motor insurance, where policy language, excess structures, and optional extras are areas where genuine comprehension failures are common and demonstrable. Behavioural research with real users provides the kind of documented, observable evidence that supports an outcome monitoring file, rather than relying on internal assertions that journeys are sufficiently clear.
Our approach
Three-Stream Capture on Your Live Journey
OpenScouter records interaction signals, voice think-aloud, and on-device facial expression simultaneously as participants move through your motor insurance quote, purchase, or renewal flow. The three streams are correlated by an AI pipeline so that a moment of hesitation on an add-on screen is matched to the participant's spoken commentary and visible expression at that exact point.
Neurodivergent Panel as a High-Signal Usability Panel
Our participants are not simply an accessibility cohort. They are a higher-signal usability panel. Cognitive differences mean they verbalise confusion that neurotypical users silently absorb. For motor insurance journeys, where policy language, pricing tables, and excess structures are inherently complex, this produces richer and more actionable findings than standard usability testing.
Human-Confirmed Reports Built for Compliance Use
Every insight in an OpenScouter report is reviewed and confirmed by a human researcher before delivery. Reports are structured around journey stages, specific friction points, and recommended changes. They are written to be useful to both design teams making fixes and compliance teams building Consumer Duty outcome evidence files.
What you receive
- Behavioural session recordings with synchronised interaction, voice, and expression streams for your motor insurance journey
- AI-correlated friction map identifying the specific screens and moments where confusion or hesitation peaks
- Human-confirmed written report structured by journey stage, from quote entry through to policy confirmation or renewal
- Prioritised list of recommended UX changes with the supporting behavioural evidence for each
- A summary document formatted for inclusion in a Consumer Duty outcome monitoring file, referencing the FCA PS22/9 framework
Frequently asked
- Which parts of the motor insurance journey can you test?
- We can run sessions on any web-based flow: initial quote and comparison screens, add-on and optional cover presentation, payment and confirmation pages, and renewal notification journeys. If your renewal flow is where customers are most likely to face a Consumer Duty scrutiny question, we can focus there specifically.
- How does this differ from what our existing analytics tools already show us?
- Tools like Hotjar show you aggregate behaviour: heatmaps, scroll depth, drop-off rates. They do not capture why a customer hesitated before accepting or declining an add-on, or what they said aloud when they saw the renewal price. OpenScouter adds the qualitative and emotional layer that analytics cannot provide, and does so in a structured, reportable format.
- Why neurodivergent participants specifically for a compliance use case?
- Neurodivergent participants verbalise confusion and friction that neurotypical users often suppress or work around silently. For motor insurance, where policy documents, pricing structures, and excess tables are genuinely complex, this means findings are richer and more specific. The FCA's Consumer Duty focus on consumer understanding maps directly onto the kinds of issues neurodivergent testers surface first.
- Are your reports legal opinions or compliance sign-offs?
- No. Our reports are behavioural evidence, not legal opinion. They document what real users experienced on your journey and what the data suggests about friction and comprehension. How that evidence is used within your Consumer Duty framework is a decision for your compliance and legal teams. We are deliberately specialised in the research and evidence layer.
- How quickly can we receive findings?
- A standard engagement moves from study brief to delivered report in days, not months. The exact timeline depends on the scope of the journey being tested and the number of sessions commissioned. We will confirm a delivery schedule at the briefing stage before any work begins.
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