What the FCA really means by consumer understanding (and why most financial promotions fall short)

How do you create FCA-compliant content that improves consumer understanding and reduces regulatory risk for financial promotions? Good question. We’ve looked at the latest FCA guidance…

What is consumer understanding according to the FCA?

Consumer understanding means ensuring that customers can:

– Understand product features, risks and costs 

– Make informed financial decisions 

– Compare products effectively 

This goes beyond accuracy. The FCA expects firms to demonstrate that their communications actually work for real customers.

Quick answer: what makes content FCA-compliant?

FCA-compliant content must be:

– Clear, fair and not misleading 

– Easy to understand for the intended audience 

– Structured to highlight key information 

– Designed to support informed decision-making 

What do you notice about all these? Together they end one very strong messgae: accuracy alone is not enough.

The problem: compliant wording doesn’t guarantee understanding

If your financial promotions are technically correct, is that enough?

The FCA says no.

Many firms still rely on compliance sign-off as proof that content works. In reality, the FCA highlights that firms often overestimate how well customers understand what they are being told.

Why this matters for marketing teams

At Alex Genn Copywriting, we have over 20 years of experience producing financial services content for firms including Lloyds Banking Group, HSBC, Santander and Invesco Perpetual.

A consistent issue we see is content that passes compliance review but fails to support genuine understanding.

This is exactly the gap the FCA is now focused on closing.

Where financial promotions fall short

Key information is buried

Important details are often difficult to find or overshadowed by promotional messaging.

Language is technically correct but unclear

Terms like “capital at risk” may be accurate but not always meaningful without context.

Structure works against comprehension

Poor hierarchy and layout make it harder for users to engage with content.

Is your content reducing risk?

If you tested your content with real users, would they understand it?

Many businesses lack the internal capability to answer that confidently. Working with a specialist copywriter for FCA compliance can help ensure content is built with both clarity and regulation in mind.

A practical framework for FCA-compliant content

Before you get started, make a note of this framework. In fact, put it on a post-it, stick it to your desk, and refer to it regularly. You won’t regret it.

  1. Clarity

Use plain English and remove unnecessary jargon 

  1. Structure

Make key information easy to find 

  1. Context

Explain risks in relatable terms 

  1. Continuity

Ensure content works across the full journey 

Why this matters now

The FCA’s focus aligns with Consumer Duty expectations around good customer outcomes. Content is no longer just marketing. It’s part of compliance.

FAQs: FCA-compliant content

What is FCA-compliant content?

Content that is clear, fair and not misleading, and enables informed decision-making.

Who is responsible for compliance?

Both marketing and compliance teams share responsibility.

Does content need to be tested?

The FCA increasingly expects firms to test communications where appropriate.

Do businesses need to hire a specialist in financial services writing?

An external agency can guarantee an up-to-date understanding of regulations, wide financial services experience and the creativity to bring it all together.

Staying compliant shouldn't be arduous

Creating FCA-compliant content requires more than technical accuracy. It requires a blend of expereice and creativity that can be hard to find. 

At Alex Genn Copywriting, we’ve been makign it easy for financial services firms to publish complaint marketign for over 20 years. From articles and whitepapers to annual reports and site content, we make sure you meet regulatory expectations.

Get in touch to discuss how we can support your next project.

Alex Genn

View posts by Alex Genn
I run a team of 25 senior-level copywriters and am myself a professional copywriter with over 15 years' experience.
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