What does the FCA say about testing?
In recent updates to their consumer duty guidelines, the FCA highlights testing as a key way to ensure consumer understanding.
This includes:
– User testing
– Behavioural insights
– Ongoing refinement
So, it’s no longer enough to make your best guess on what works, the FCA expects more.
Quick answer: why testing matters
Try not to think of it as another imposition or barrier to you getting your message over. Testing is incredibly useful to business.
It can help you identify misunderstandings. The process can give you a laser focus on clarity, and certainty of approach.
And beyond that it can support you with evidence compliance.

The dangerous gap for most businesses

Over the last 20 years, working with financial services businesses, we’ve seen many businesses that rely solely on internal review processes.
The truth is, while that’s a useful process, what it doesn’t give you is real customer understanding.
It’s only by undertaking specific audience research, that you can be sure you’re not only really connecting with your audience, but that you’re avoiding the pitfalls which will mean you fall foul of the FCA.
In short, if you’re only testing internally, you’re creating dangerous blind spots.
The right experience counts
The fact is, FCA compliance is a tricky beast. One of the easiest ways to avoid falling foul of the rules is to make sure your team has the right experience, as well as the ability to stay aware of the latest updates. For many financial services businesses, outsourcing to experts can bring peace of mind.
At Alex Genn Copywriting, our 25 senior-level copywriters have an abundance of experience in financial services. They make it their business to stay up to date on the regulations, complement their creativity, sharp interviews, quality research and authoritative writing.
Evidence and testing - a practical approach check
Do you have evidence that your audience understands your content?
If not, you may be opening yourself up to a potential compliance risk. We’ve been through the most recent updates to the regulations and put together a simple approach to help you get it right…
A practical approach to testing
- Define key messages: What is it that’s most important for users understand?
- Test with real users: Gather feedback on comprehension from actual people
- Refine content: Iterate and improve based on insights, and make sure you keep a record
- Repeat: Make testing part of your process, every time
If you follow these fairly straightforward steps, you’ll be more likely to stay on the right side of the FCA.

FAQs about FCA compliance an testing
Is testing mandatory?
Not always, but increasingly expected.
What should be tested?
Any content that influences financial decisions.
Does this apply to all content?
Yes. The principles apply across all financial promotions and business writing.
What is FCA-compliant content?
Content that is clear, fair and not misleading, and enables informed decision-making.
Put us to the test
Testing is not just a compliance exercise. It’s a genuinely valuable way to improve the performance of your marketing communications.
At Alex Genn Copywriting, our client experience includes: Invesco, Rathbones, Santander, HSBC, CMC Markets, Atradius Credit Insurance, Moody’s Analytics, Close Brothers, St James’s Place, The Trident Trust, The Virgin Group and many others.
We support a wide range of financial services brands from global giants and SMEs to disruptive fintech startups, to create powerful content that’s as compliant as it is effective.
Get in touch to discuss your next project.
