Why the FCA focuses on journeys, not just individual content
Most marketing teams naturally think in terms of individual assets.
A landing page. An email. A brochure.
Each piece is created, reviewed and approved on its own terms. But from a regulatory perspective, this is only part of the picture.
The FCA has made it clear that customer understanding is shaped by the entire journey, not just isolated communications. Under Consumer Duty, businesses are expected to consider how information is presented, repeated and reinforced over time, and whether that overall experience enables customers to make informed decisions.
This represents a shift in responsibility. It is no longer enough for individual pieces of content to be compliant in isolation. They must work together as part of a coherent, structured journey.
Quick answer: what makes a customer journey FCA-compliant
A compliant customer journey is one that actively supports understanding from start to finish.
This means that communications should not simply exist as standalone touchpoints. Instead, they should guide customers through a logical progression, where each interaction builds on the last.
In practice, this involves:
– Introducing key concepts early and reinforcing them over time
– Presenting information in manageable stages rather than all at once
– Ensuring consistency across channels and formats
– Making it easy for customers to revisit and compare information
When these elements are missing, even well-written content can fail to meet FCA expectations.
Where customer journeys typically break down
In many organisations, content is created in silos. Different teams are responsible for different channels, and while each piece may be reviewed individually, there is often limited coordination across the full journey. Over time, this leads to a fragmented experience.
As a result, your customers may encounter:
– Slightly different explanations of the same product
– Inconsistent emphasis on risks and benefits
– Gaps in information at key decision points
The FCA highlights that firms should not assume customers will piece together information themselves. If the journey is not designed intentionally, misunderstandings become far more likely.
This is where risk begins to build, often in ways that are not immediately visible internally.
Our insight: why journeys fail in practice
At Alex Genn Copywriting, we regularly work with firms that have strong individual content but weak overall journeys.
The issue is rarely a lack of effort. In fact, many organisations produce a high volume of content across multiple channels.
The problem is that this content has not been designed to work together.
Without a clear structure, important messages are diluted, repeated inconsistently or introduced too late in the process. From a regulatory perspective, this makes it harder to demonstrate that customers are being supported effectively.
From objective and audience understanding, through to information hierarchy, core messaging and final content, our senior-level writers have the experience to deliver a coherent, consistent, effective customer journey.
Does your content work as a journey?
A useful way to assess this is to step back and look at the full experience from a customer’s perspective. This is a particular skill and it takes a little time to master. Really imagine yourself in their shoes, think about what they’re looking for, what’s important to them and what might be a barrier to understanding.
Ask yourself:
– What does a customer see first?
– What do they see next?
– How does each interaction build on the previous one?
If the answers are unclear, or if different parts of the journey feel disconnected, there is a strong chance that the overall experience is not supporting understanding as effectively as it should.
This is where working with a specialist copywriting agency can help bring structure and consistency to the process.
FCA-compliant customer journeys - key principles
At Alex Genn Copywriting, we regularly work with firms that have strong individual content but weak overall journeys.
The issue is rarely a lack of effort. In fact, many organisations produce a high volume of content across multiple channels.
The problem is that this content has not been designed to work together.
Without a clear structure, important messages are diluted, repeated inconsistently or introduced too late in the process. From a regulatory perspective, this makes it harder to demonstrate that customers are being supported effectively.
From objective and audience understanding, through to information hierarchy, core messaging and final content, our senior-level writers have the experience to deliver a coherent, consistent, effective customer journey.
Designing an effective journey doesn’t require starting from scratch. In most cases, it’s about organising and refining what already exists. A useful way to approach this is through four key principles.
Consistency
Consistency is about more than tone of voice. It ensures that key messages, particularly around risks and features, are aligned across all channels.
When customers encounter conflicting or inconsistent information, it creates confusion and undermines trust. The FCA expects you to manage this proactively rather than assuming it will not be an issue.
A consistent approach makes it easier for customers to build understanding over time.
Reinforcement
Important information shouldn’t be presented once and then left behind. The FCA highlights the value of “layering” information, where key messages are introduced early and then reinforced in different formats and at different stages of the journey.
This helps customers absorb complex information gradually, rather than being overwhelmed at a single point in time.
Reinforcement is particularly important for risk-related information, which should remain visible throughout the journey.
Progression
A well-designed journey has a clear sense of progression. Customers should move from general understanding to more detailed information in a logical sequence. Each step should prepare them for the next, rather than introducing entirely new concepts without context.
When progression is missing, customers are often forced to process too much information at once or fill in gaps themselves. This increases the likelihood of misunderstanding.
Accessibility
Finally, journeys must be accessible to a wide range of customers. This includes not only technical accessibility but also the ability to understand and engage with the content. The FCA expects you to consider different levels of financial knowledge and potential vulnerabilities.
Content that works for one audience may not work for another. A compliant journey takes this into account from the outset.
Why this matters under Consumer Duty
Recent guidance places a strong emphasis on supporting customers throughout their relationship with a business, not just at the point of sale.
This means that you need to consider how understanding develops over time and whether their communications continue to support good outcomes.
A fragmented or poorly structured journey can undermine this, even if individual pieces of content appear compliant.
On the other hand, a well-designed journey provides clear evidence that your business is actively supporting customer understanding.
FAQs on FCA compliance
What is an FCA-compliant customer journey?
An FCA-compliant customer journey is a sequence of communications that work together to help customers understand a financial product, its risks and its features over time. Rather than relying on a single piece of content, the journey should build understanding step by step and support informed decision-making at every stage.
Does the FCA assess individual content or the full journey?
The FCA assesses the overall customer experience, not just individual pieces of content.
This means firms must consider how communications interact across channels and whether the combined effect supports customer understanding and good outcomes.
Why is consistency across channels important for compliance?
Inconsistent messaging across channels can confuse customers and lead to misunderstandings.
The FCA expects firms to ensure that key information, particularly around risks and product features, is aligned across all touchpoints.
Consistency helps reinforce understanding and reduces regulatory risk.
How can marketing teams improve customer journeys?
Marketing teams can improve journeys by:
– Mapping the full customer experience
– Identifying gaps or inconsistencies in messaging
– Ensuring key information is introduced and reinforced clearly
– Structuring content to guide customers step by step
This often requires collaboration across teams rather than isolated content creation.
Do customer journeys need to account for vulnerable customers?
Yes. The FCA expects firms to consider a range of customer needs, including vulnerability. This includes ensuring that content is accessible, clearly structured and easy to understand for different levels of financial knowledge and capability.
What is meant by “layering” information?
Layering involves presenting key information upfront and then providing additional detail progressively, helping customers build understanding over time.
Does every touchpoint need to be compliant?
Yes. The FCA assesses the overall experience, not just individual communications.
No-one is an island. Isolation = risk
If your content is crafted in isolation, it may be creating unnecessary risk.
At Alex Genn Copywriting, we help financial services businesses design structured, FCA-compliant content journeys that improve clarity and consistency across every touchpoint.
Over the last 20 years, we’ve worked with some of the world’s largest brands, such as HSBC, Invesco, Santander, American Express, Rathbones, Tesco and The Virgin Group, as well as many SMEs and disruptive fintech startups.
Our 25 senior-level writers work in close collaboration with your team, sharing their financial expertise and creativity, to guarantee a successful outcome every time.
Get in touch to discuss how we can support your content strategy.