Consumer Duty UX evidence
Consumer Duty UX Evidence for Pension Providers
The FCA expects pension providers to show that member communications actually work, not just that they were sent. OpenScouter delivers behavioural research reports that give your compliance and design teams documented, human-confirmed evidence from real users.
Pension Providers Face a Specific Evidential Gap Under Consumer Duty
Consumer Duty, introduced under PS22/9, requires firms to demonstrate good outcomes for retail customers. For pension providers, that obligation extends to the clarity of benefit statements, the usability of retirement income calculators, and the comprehensibility of transfer value disclosures. Regulatory intent is clear: evidence of outcome, not evidence of effort.
Most pension providers have governance documentation, accessibility statements, and design rationale. What they often lack is behavioural evidence from real consumers showing that those journeys produce the outcomes the firm intends. That gap is precisely what the FCA is examining in multi-firm reviews.
Neurodivergent members, people with ADHD, dyslexia, or cognitive differences, are disproportionately likely to disengage from complex pension communications. They are also the users most likely to miss a critical decision point on a drawdown or consolidation journey. Their behaviour in a research session surfaces issues that standard usability testing does not.
The FCA expects firms to evidence that consumer communications work, not just that they were sent, with testing against real consumers as a baseline expectation
For pension providers, this FCA finding carries particular weight. Pension communications are among the most consequential documents a retail consumer receives: they inform decisions about retirement income, transfer values, and drawdown options that are difficult or impossible to reverse. A firm that can only show it sent a benefit statement or published a disclosure, without evidence that members understood it, is exposed under Consumer Duty in a way that a behavioural research report directly addresses. OpenScouter sessions create exactly the kind of documented, consumer-facing evidence the FCA describes as a baseline expectation, tested against real users on real journeys.
Our approach
Regulatory framing built into the study design
Every OpenScouter engagement for pension providers is scoped against the specific Consumer Duty outcomes your compliance team needs to evidence. We map session tasks to FCA outcome categories before a single participant is recruited, so the resulting report speaks directly to your regulatory obligations rather than generic usability metrics.
Three-stream capture across real pension journeys
Participants complete tasks on your actual product: logging into a member portal, reviewing a pension summary statement, or stepping through a retirement income projection tool. We capture interaction signals, think-aloud voice, and facial expression in parallel. The AI pipeline correlates all three streams. A human researcher confirms every insight before it enters the report.
Reports your compliance and design teams can both use
OpenScouter reports are structured so that a compliance officer can cite the findings in a Consumer Duty board report and a product designer can act on them in the next sprint. We do not produce legal opinion. We produce documented behavioural evidence, with session recordings, annotated transcripts, and a prioritised issue log.
What you receive
- Scoped study brief mapped to FCA Consumer Duty outcome categories relevant to your pension product
- Remote sessions with neurodivergent participants completing real tasks on your member portal or communications
- Three-stream behavioural data capture: interaction signals, think-aloud voice, and on-device facial expression processing
- AI-correlated insight report, human-confirmed before delivery, with annotated session evidence
- Prioritised issue log formatted for both compliance documentation and design team sprint planning
Frequently asked
- Which pension journeys can OpenScouter test?
- Any journey accessible via a browser or web-based member portal. Common scopes include pension summary statement pages, retirement income calculators, transfer value disclosure flows, and drawdown selection journeys. If your communications are delivered as PDFs or embedded documents, we can test the surrounding navigation and the document reading experience.
- How does this relate to our existing Consumer Duty governance process?
- OpenScouter reports are designed to sit alongside your existing governance documentation as behavioural evidence. They do not replace legal review, actuarial sign-off, or your internal compliance framework. They provide the consumer-facing evidence layer that PS22/9 expects firms to hold: documented proof that communications work for real users, including users with cognitive differences.
- Are your participants representative of pension scheme members?
- Our neurodivergent panel is recruited for higher-signal usability research, not demographic representativeness. Participants with ADHD, dyslexia, autism, and related cognitive differences surface friction that neurotypical users often tolerate or work around. For pension providers, this matters because disengagement and misunderstanding are the failure modes the FCA is most concerned with.
- How long does a study take from brief to report?
- A focused study scoped to one or two pension journeys typically completes within two to three weeks from brief sign-off to delivered report. Broader studies covering multiple touchpoints, such as a full member portal review, take longer and are scoped individually. We will give you a timeline before any work begins.
- Can the report be shared with the FCA or used in a regulatory submission?
- Yes. The report is your document. Firms have used OpenScouter reports as supporting evidence in Consumer Duty board papers and in responses to FCA information requests. We recommend involving your legal and compliance teams in deciding how and where to cite the findings. Our reports are evidence, not legal opinion.
Keep reading
Research hub
Use case
Related research
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.