vulnerable customer testing
Vulnerable Customer Testing for Retail Investment Platforms
Retail investment platforms carry a regulatory duty to treat vulnerable customers fairly. OpenScouter runs behavioural research sessions with neurodivergent participants and surfaces the usability friction that puts those customers at risk, before the FCA asks questions.
The FCA Expects Evidence, Not Intentions
Under FCA Finalised Guidance FG21/1 and the Consumer Duty rules introduced in PS22/9, retail investment platforms must demonstrate that their products and services deliver good outcomes for all customer types, including those in vulnerable circumstances. Intention is not enough. Firms need documented evidence that their interfaces do not create additional harm.
The journeys that matter most on a retail investment platform are also the ones most likely to trip up a vulnerable customer: opening an account under time pressure, understanding a risk-warning disclosure before placing a trade, navigating a drawdown or withdrawal flow when financial stress is already elevated. These are not edge cases. They are the moments regulators scrutinise.
Standard analytics tell you where customers drop off. They do not tell you why a customer froze on the risk-appetite questionnaire, misread a charges summary, or abandoned a transfer-in mid-flow. Behavioural research with the right participant panel fills that gap with observable evidence, not assumptions.
FCA defines a vulnerable customer as someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care
For retail investment platforms, the FCA's definition of vulnerability carries direct commercial and regulatory weight. Investment journeys involve financial decisions made under conditions of stress, uncertainty, and cognitive load. A customer who is susceptible to harm in those conditions may misread a risk warning, misunderstand a fee structure, or make an irreversible transaction without realising it. The FCA's guidance makes clear that the obligation sits with the firm: appropriate levels of care must be built into the product and the interface, not just the customer service script. Behavioural research with neurodivergent participants is the method that makes that care observable and documentable.
Our approach
A participant panel that finds what others miss
OpenScouter recruits neurodivergent participants including people with ADHD, dyslexia, autism, and anxiety-related conditions. These testers surface usability failures on account-opening flows, KYC screens, and investment-selection journeys that neurotypical test groups consistently overlook. They are a higher-signal panel, not a specialist niche.
Three data streams captured in parallel
Every session records interaction signals (clicks, scrolls, rage clicks, hesitation patterns), think-aloud voice commentary, and facial expression data processed locally on the participant's device. The three streams are correlated by an AI pipeline so you can see, for example, that a participant verbally expressed confusion at the same moment they repeatedly clicked a non-interactive element on your charges disclosure page.
Human-confirmed reports your compliance team can use
AI correlation produces the initial analysis. A human researcher reviews every finding before the report leaves OpenScouter. What you receive is a structured, evidence-backed document that maps observed behaviour to specific interface elements, with prioritised recommendations. It is evidence your team can act on and, if needed, present to the FCA.
What you receive
- Session recordings with synchronised interaction, voice, and facial expression streams for each participant
- AI-correlated findings report reviewed and confirmed by a human researcher
- Journey-level friction map covering the specific flows you nominate, such as account opening, risk-warning acceptance, or withdrawal
- Prioritised recommendations tied to named interface elements, not general design principles
- A written summary suitable for inclusion in your Consumer Duty outcome-monitoring documentation
Frequently asked
- Which customer journeys on a retail investment platform are most relevant to test?
- Account opening and KYC, risk-appetite questionnaires, charges and fee disclosures, investment selection and order placement, and withdrawal or drawdown flows are the journeys most likely to create harm for vulnerable customers. We can test any combination. Most clients start with the onboarding flow because that is where the FCA focuses its Consumer Duty reviews.
- How does this relate to our Consumer Duty obligations under PS22/9?
- Consumer Duty requires firms to evidence good outcomes across the customer base, including for customers in vulnerable circumstances. A behavioural research report from OpenScouter gives you documented, session-level evidence that you have tested your interface against a vulnerable customer panel and acted on what you found. That is the kind of evidence that supports a credible outcome-monitoring framework.
- Are your participants actually vulnerable customers, or just neurodivergent testers?
- Our panel is neurodivergent, not clinically assessed as financially vulnerable. The FCA's definition of vulnerability covers a wide range of circumstances, and cognitive differences are explicitly within scope. Neurodivergent participants reliably surface the interface friction that creates risk for a broad range of vulnerable customers. We are transparent about what the panel is and what it is not.
- How long does a study take from brief to report?
- A focused study covering one or two journeys typically completes within two weeks of brief sign-off. Larger engagements covering multiple flows take longer. We scope each project individually and give you a timeline before work begins.
- Can OpenScouter work alongside our existing UX research or compliance teams?
- Yes. OpenScouter is a complement to in-house design and research teams, not a replacement. We are also a complement to tools you may already use for quantitative analytics. Our reports are evidence, not legal opinion, and we do not provide regulatory advice. Your compliance team interprets the findings in the context of your obligations.
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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.