Consumer Duty customer communications: rules, testing and the CCM platform to run them

Consumer Duty customer communications have one job: help your customers understand enough to make good decisions. The FCA doesn’t just want clear letters. It wants proof you tested them, watched what happened and fixed what didn’t work.

That proof lives in your customer communications management (CCM) platform, or it doesn’t exist. This guide covers what the rules ask, what a platform has to do to support them, and which CCM vendors fit UK banks, insurers, lenders and wealth firms. It isn’t legal advice. For the full vendor list, see our CCM software guide.

Pick by your situation

Short on time? Start here.

• Want the most proven all-rounder with a UK building society presence? Look at Quadient Inspire.
• Huge content library to simplify and keep consistent? Look at Messagepoint.
• Want readability and sentiment checks inside authoring? Look at Precisely EngageOne.
• Statement-heavy and want a financial services specialist? Look at Doxim.
• Running SmartCOMM today? Jump to renewal and exit terms.

What the Consumer Duty asks of your communications

The Duty has applied since 31 July 2023 to products open to sale or renewal, and since 31 July 2024 to closed books. Consumer understanding is one of its four outcomes, set out in PRIN 2A.5 of the FCA Handbook.

Three tests every communication has to pass

PRIN 2A.5.3 says your communications must “meet the information needs of retail customers”, be “likely to be understood by retail customers” and “equip retail customers to make decisions that are effective, timely and properly informed”. They must also be clear, fair and not misleading.

That’s a test of outcome, not wording. A letter can be accurate and still fail.

How the FCA expects you to write

PRIN 2A.5.7 is guidance, and it reads like a style guide. Present information logically. Use plain language and explain jargon you can’t avoid. Make key information prominent with headings, layout, tables and graphics. Cut unnecessary disclaimers. Don’t bury the decision under detail.

Tailor to the customer, including vulnerability

PRIN 2A.5.8 asks you to take into account customers’ characteristics, “including any characteristics of vulnerability”, along with product complexity and the channel. In one-to-one interactions, PRIN 2A.5.9 asks you to tailor where appropriate and check the customer understands.

Choose the channel and the moment

You must send information in good time for customers to decide, both before purchase and at the right points in the product’s life (PRIN 2A.5.5). The channel has to let customers review the information and weigh their options (PRIN 2A.5.6). A renewal notice that lands after the auto-renewal date fails, however well it’s written.

Test, monitor, fix: the loop your platform has to support

This is where most firms struggle, and where your CCM platform matters most. PRIN 2A.5.10 says that, where appropriate, you must test communications before sending, monitor their impact regularly, then investigate and correct any problem you find.

You don’t have to test everything. PRIN 2A.5.12 lists the factors: whether the communication prompts a decision, how many customers it reaches, their information needs, vulnerability, the scope for harm and whether speed matters more than testing.

1. 1

   Draft for your actual customers

   PRIN 2A.5.3, 2A.5.7, 2A.5.8

   The FCA asks

   Plain language, key information made prominent, tailored to customer characteristics including vulnerability.

   Your CCM platform

   Approved content blocks reused across letters, readability checks while authoring, variants for large print, audio or Braille driven by customer data.

   Proof to ask for

   Change one approved clause and show every template that uses it.

2. 2

   Test before you send

   PRIN 2A.5.10(1)(a), 2A.5.12

   The FCA asks

   Test where appropriate, judged by the decision at stake, reach, vulnerability and harm.

   Your CCM platform

   Generate A and B variants and test proofs from real data, and lock the tested version so it’s the one that goes out.

   Proof to ask for

   Two variants of one letter, and a record linking the test result to the released version.

3. 3

   Send on the right channel, in time

   PRIN 2A.5.5, 2A.5.6

   The FCA asks

   Information in good time for the decision, through a channel that lets customers review it.

   Your CCM platform

   Event triggers tied to deadlines, channel rules, and a single preferences profile so customers tell you their needs once.

   Proof to ask for

   A renewal notice generated from the policy date, with proof of when it was sent and by which channel.

4. 4

   Monitor the impact

   PRIN 2A.5.10(1)(b), PRIN 2A.9

   The FCA asks

   Regularly monitor whether communications support good outcomes.

   Your CCM platform

   Record which version and variant each customer got, with delivery, open and return data you can join to complaints and call data.

   Proof to ask for

   An export of one month’s letters by version, channel and customer segment.

5. 5

   Investigate and fix

   PRIN 2A.5.10(2)

   The FCA asks

   Investigate issues, adapt the communication, and change the product or process if wording alone won’t fix it.

   Your CCM platform

   Fast edits by business users under approval workflow, full change history, and a re-test before re-release.

   Proof to ask for

   The audit trail for one change: who edited, who approved, when it went live.

6. 6

   Report to the board

   PRIN 2A.8

   The FCA asks

   At least once a year, the governing body reviews and approves a report on customer outcomes.

   Your CCM platform

   Management information on communications by segment, including vulnerable customers, ready for the outcomes report.

   Proof to ask for

   A sample outcomes dataset for communications, split by customer group.

↺ What you learn at step 6 feeds the next draft at step 1.

Rules: FCA Handbook PRIN 2A.5, 2A.8 and 2A.9, read November 2026. The CCM and proof columns are our mapping of the rules to platform capabilities, not FCA text.

The weakest link is usually step 4. If your platform can’t tell you which version of a letter each customer received, you can’t link a spike in complaints back to a template.

What the FCA found when it checked

In September 2025 the FCA surveyed 38 firms across insurance, retail banking, payments, consumer finance and CFD providers. It published the results in March 2026. The examples don’t create new rules, but they show what supervisors look for.

Here’s who’s reading your letters, according to figures the FCA cited.

Who your customers are	Share
Adults with limited understanding of their products	12%
Adults with low everyday numeracy confidence	19%
Adults with poor or low financial numeracy	34% (17.7 million)
Adults with literacy at or below the level expected of a 9 to 11-year-old	About 1 in 7

Source: FCA, Consumer understanding: good practice and areas for improvement (March 2026), citing its Financial Lives survey and other research.

What good looked like

Firms tested before and after changes, using short surveys, comprehension checks, A/B tests and customer callbacks, and wrote down what changed and why. One firm redrafted until customers recalled at least 80% of key points correctly. A small firm tested a renewal letter with customers including two with sight impairments, then added large print and a 100-word summary.

Firms also used “tell us once” profiles that adjusted letters, emails and call-handler prompts automatically. That’s a data job your CCM platform has to read from.

Where firms fell short

The FCA found testing often “superficial, one-off or poorly documented”, sometimes with groups too small to mean much. Some changes were cosmetic, like shorter wording or new colors, without fixing the cause. Long documents lacked summaries and signposting.

Some firms treated an absence of complaints as proof of understanding. The FCA said that “does not provide reliable assurance”. Its summary line: “Firms must not only monitor but also act on what the monitoring reveals.”

Vulnerable customers: FG21/1 meets your templates

The FCA’s FG21/1 guidance defines a vulnerable customer as “someone who, due to their personal circumstances, is especially susceptible to harm”. It names four drivers: health, life events, resilience and capability.

For communications, it asks you to make everything understandable for your customer base and, where possible, offer more than one channel. Its example: changing a process that would usually send automated letters, so a customer with a visual impairment gets Braille or audio instead. It also reminds firms of their duties under the Equality Act 2010.

In practice that means your CCM platform reads a needs flag and changes the output, on every letter, without someone remembering to do it by hand. The FCA’s 2025 vulnerability review flagged customers who had to repeat their needs because adjustments weren’t made. Our accessible customer communications guide covers PDF and digital accessibility standards in depth.

Changes the FCA has proposed

In June 2026 the FCA consulted on changes to the Duty (CP26/23). It proposes that firms with no role in preparing communications wouldn’t need to meet the consumer understanding outcome, that UK firms wouldn’t need to test non-UK customers’ understanding, and that the board report needn’t be a stand-alone document.

These are proposals, not rules. The consultation closed on 18 September 2026 and the FCA expects to publish its policy statement in Q1 2027. None of them removes the test, monitor and fix loop.

SmartCOMM alternatives for UK firms

Few CCM vendors have independent, public UK financial services evidence; most UK customer stories sit on vendor sites. The picks below lead with what can be checked. Ratings aren’t UK-specific, and every number is in our CCM benchmark.

1

Quadient Inspire

Best for banks, building societies and insurers that want the most proven all-rounder

• 4.8 ★130 Gartner reviews
• BSAassociate member and conference exhibitor

The deepest review record in CCM. Quadient UK exhibits at the Building Societies Association conference and co-hosted a 2023 BSA webinar on building society communications. Run it as SaaS, on-premises or hybrid.

Watch out: its named UK bank stories are vendor-published, so ask for two UK references you can call.

SmartCOMM vs Quadient Inspire →

2

Messagepoint

Best for firms whose Consumer Duty problem is a big, inconsistent content library

• 4.4 ★69 Gartner reviews
• LuminaryCelent insurance CCM 2024, per Messagepoint

Messagepoint manages communications as shared content, so one fix flows into every letter that uses it. It says its MARCIE AI analyzes plain language, reading levels and sentiment. It exhibits at the BSA conference and pitches building societies directly.

Watch out: UK building society material is vendor-written, with no named customers; ask for UK references.

SmartCOMM vs Messagepoint →

3

Precisely EngageOne

Best for teams that want readability and risk checks inside authoring

• 4.1 ★12 Gartner reviews
• Dec 2025Readability agent announced

Precisely announced Readability, Sentiment Analysis and Contextual Rewrite agents for EngageOne RapidCX in December 2025. In September 2026 it announced compliance risk scoring and PII masking agents, both with audit logs.

Watch out: the review base is small, so lean on reference calls with UK firms.

SmartCOMM vs Precisely EngageOne →

4

OpenText Exstream

Best for very high-volume statement and notice runs

• 4.4 ★76 Gartner reviews

Reviewers praise fast, reliable batch runs. UK Contracts Finder shows the DWP buying Exstream review and consultancy from OpenText and the DVLA buying OpenText consultancy for an upgrade, so UK delivery capacity exists, though in the public sector.

Watch out: its UK building society stories are vendor-published; ask for a UK financial services reference at your volume.

SmartCOMM vs OpenText Exstream →

5

Doxim

Best for statement-heavy lenders, building societies and wealth firms

• Major PlayerIDC MarketScape 2026, per Doxim
• 2020entered UK by buying Striata

Doxim focuses on financial services. It bought Striata in 2020, partly to enter the UK, and in 2021 launched a UK CCM offer aimed at uses like building society statements and insurance policy updates.

Watch out: few public reviews and no named UK clients, so ask for references.

See Doxim in the CCM benchmark →

Check the UK evidence yourself

Use this table in your first vendor call. The right answer is a named UK firm you can phone, not a logo slide.

Platform	UK evidence you can check	Ask the vendor
Quadient Inspire	BSA associate member and conference exhibitor	Two UK bank or insurer references on Consumer Duty work
Messagepoint	BSA conference exhibitor	A UK firm that used it to simplify letters, with before and after
Precisely EngageOne	Readability agent announcement (press release)	Whether UK firms use the agents in production
OpenText Exstream	UK public-sector contracts	A UK financial services reference at your volume
Doxim	UK entry via Striata, UK launch in trade press	Named UK clients and where your data is hosted

Also need sector detail? See our CCM guides for banks, insurers and wealth managers.

Running SmartCOMM today? Start with renewal and exit terms

Smart Communications started in the UK. Bloomberg Law describes it as a UK technology firm that was part of UK software company Thunderhead until a 2016 spin-out. Cinven agreed to buy a majority stake in August 2025. If you’re on SmartCOMM, your contract dates decide how much room you have.

1. Find the notice date in your order form and work back about a year. Our SmartCOMM contract renewal plan has the timeline.
2. Get your Consumer Duty evidence out. Version history, approval records, test variants and delivery data are what show the FCA you tested, monitored and fixed. Get an export of all of it, with metadata, written into the contract.
3. Get template and content export terms in writing, including content blocks and the rules that pick variants for vulnerable customers.
4. Ask for a short extension sized to a migration, with per-unit prices and an increase cap, instead of a long renewal.
5. Price a competitor on the same volumes. Start with SmartCOMM alternatives, then plan the move with our guide to migrating off SmartCOMM.

What to put in your RFP

These lines follow from PRIN 2A.5 and the FCA’s findings. Untick what doesn’t apply, then copy them. Our CCM RFP template has the rest.

Content and understanding

Reusable approved content blocks, with every template that uses a block listed. Readability and plain-language checks during authoring. Variant rules driven by customer data, including vulnerability flags and format needs (large print, audio, Braille). Summaries and layered content for long documents.

Testing and release

A and B variants of the same communication from one template. Test proofs generated from real or masked customer data. A lock that ties the tested version to the released version.

Delivery and monitoring

Event triggers tied to decision deadlines, with proof of send time and channel. A single customer preferences profile used by every channel. Per-customer record of which version and variant was sent. Export of delivery, open and return data by version and segment.

Governance and exit

Business-user editing under approval workflow with a full audit trail. Management information for the annual board outcomes report. Full export of templates, content, version history and audit records, priced in the contract.

Create RFP lines

How to test the shortlist

Use your own letters, the ones customers act on.

1. Change one clause in a shared block and show every affected template, the approval and the audit trail.
2. Build two variants of a renewal or arrears letter and show which customers got which.
3. Flag a test customer as needing large print and send three different communications. All three should change.
4. Export a month of sends by version, channel and segment, as your board report would need.
5. Score each vendor with our CCM vendor scorecard.

Running communications in Australia too? See CCM and Australian disclosure rules.