The Financial Conduct Authority has announced its Consumer Duty priorities for 2026, and the message is clear. The regulator is shifting from implementation to enforcement.
For financial services brands, this means every customer touchpoint from your website andbrand messaging to your marketing campaigns will face increased scrutiny.
At Creode, we've spent over 15 years working with financial services brands. We've seen regulatory shifts before, but Consumer Duty represents something different. It's not just about compliance - it's about rethinking how marketing and digital experiences deliver genuine customer value.
Here's what's changing in 2026, and how we're evolving our services to help clients navigate this new landscape.
The FCA has outlined an ambitious programme of work for 2026, with several key developments that will directly impact how FS brands approach marketing and digital experience:
The first half of 2026 will see consultations on:
How Consumer Duty applies across distribution chains, including proposals to limit scope to UK customers only
Updates to client categorisation frameworks to ensure sophisticated investors aren't subject to unnecessary retail protections
Next steps on Financial Ombudsman Service alignment and complaint handling reforms
Q1 2026 brings:
Joint FCA and Information Commissioner's Office guidance on balancing Consumer Duty with data protection and vulnerability requirements
Consultation on revised consumer credit advertising rules
Mid-2026 includes:
Consultation on the international application of insurance conduct rules
The FCA will conduct multi-firm reviews examining how companies are delivering across four critical outcomes:
Products and services outcome - How firms design products and services to meet customer needs, including those with characteristics of vulnerability
Outcomes monitoring - How firms respond to outcomes monitoring requirements and demonstrate they're tracking customer outcomes
Customer journey design - The design and delivery of customer journeys, with particular focus on how firms apply friction throughout the journey
Consumer understanding outcome - How communications help consumers make informed decisions
These reviews affect every financial services sector - retail banking, insurance, wealth management, consumer credit, and fintech.
The FCA is also targeting specific areas where it sees potential consumer harm:
Retail banking: Fair value in SME business current accounts
Consumer credit: How consumers understand credit card terms and conditions, particularly promotional offers
Consumer investments: Complex exchange-traded products (findings early 2026) and model portfolio services (findings summer 2026)
Insurance: Pure protection market study examining consumer engagement and understanding
The regulatory focus has shifted to the customer-facing elements that marketing teams control: websites, brand communications, and campaign execution. The FCA expects robust evidence that you're delivering good outcomes, not just box-ticking compliance.
The challenge for financial services brands is clear: you need digital experiences and campaigns that are compliant, clear, and conversion-focused - without sacrificing performance or brand impact.
Through our work with banks, building societies, insurers, and fintechs, we've identified four common gaps in how financial services brands approach Consumer Duty:
Websites built for compliance teams, not customers. Legal and compliance requirements often dominate the user experience, resulting in cluttered interfaces, buried information, and poor conversion rates. The FCA's focus on consumer understanding and customer journey design means this approach won't pass scrutiny.
Generic brand positioning that doesn't demonstrate value. Many financial services brands rely on generic messaging about trust, expertise, and customer service. Under the products and services outcome review, the FCA wants evidence that your brand positioning genuinely meets customer needs and delivers differentiated value.
Campaigns optimised for volume, not informed decisions. Performance marketing in financial services has traditionally focused on clicks, leads, and conversions. The FCA's outcomes monitoring requirements mean you need to demonstrate that campaigns help customers make informed decisions, not just drive volume.
Inconsistent messaging across channels. When brand messaging, website content, and campaign materials tell different stories, customers get confused. The FCA's customer journey reviews examine the end-to-end experience, not individual touchpoints in isolation.
We've always believed that good marketing and good customer outcomes aren't mutually exclusive. The best financial services brands do both, they drive commercial results whilst genuinely serving customer needs. Consumer Duty reinforces this philosophy.
Here's how we're evolving our services to help clients navigate the 2026 requirements:
Our approach to website development has evolved to explicitly address the FCA's consumer understanding and customer journey design requirements.
We're building sites that:
Prioritise clarity over legal coverage - Information architecture that helps customers find what they need and make informed decisions, with compliance requirements integrated seamlessly rather than dominating the experience
Use friction appropriately - Strategic friction points that protect customers and ensure understanding, without creating unnecessary barriers to conversion
Demonstrate accessibility - Inclusive design that meets the needs of vulnerable customers, with clear evidence of how the site serves different customer segments
Our Mosaic CMS platform exemplifies this approach. Built specifically for financial services, it empowers marketing teams with the tools to maintain brand consistency and regulatory compliance while updating content quickly and independently. It is visual, intuitive, and fundamentally designed to make compliant content customer-friendly.
And we’re proud to partner with AudioEye, a leading digital accessibility platform, to help organisations create inclusive digital experiences. This partnership strengthens our commitment to building financial services platforms that serve everyone, combining our expertise in regulatory-compliant design with AudioEye's cutting-edge accessibility technology to deliver experiences that are both compliant and genuinely inclusive.
The FCA's focus on the products and services outcome means brand positioning needs to demonstrate genuine customer value, not just marketing differentiation.
We're developing brand strategies that:
Start with customer needs - Deep research into what customers actually need from financial services, including vulnerable segments, rather than what brands want to say about themselves
Articulate clear value propositions - Specific, evidenced claims about how products and services meet customer needs, not generic statements about trust and expertise
Create differentiation through delivery - Positioning based on how you genuinely serve customers differently, with evidence to back it up
This approach helps brands pass regulatory scrutiny whilst building stronger commercial differentiation. When your brand positioning is rooted in genuine customer value, it resonates more powerfully in the market.
The FCA's outcomes monitoring requirements and upcoming advertising rules consultation mean campaigns need to demonstrate they're helping customers make informed decisions, not just driving conversions.
We're creating campaigns that:
Balance performance with understanding - Optimising for both conversion metrics and evidence of informed decision-making
Built-in outcomes tracking - Measurement frameworks that capture whether customers understood what they were buying, not just whether they bought it
Maintain consistency across channels - Integrated campaigns where messaging, creative, and customer journey work together to support understanding
Our experience with performance marketing in financial services, across SEO, PPC, paid social, and email, means we understand how to drive results within regulatory constraints. We've been doing this for banks, insurers, and consumer credit brands for over 15 years.
Perhaps most importantly, we're taking an integrated approach that recognises the FCA is examining end-to-end customer journeys, not isolated touchpoints.
This means:
Aligning brand, digital, and campaign strategy - Ensuring your website, brand positioning, and campaign execution tell a consistent story that supports customer understanding
Mapping and optimising journeys - Identifying where customers struggle to understand products or make decisions, and redesigning those touchpoints
Building evidence frameworks - Creating systems to capture and demonstrate good outcomes across the entire customer journey
Consumer Duty reinforces why we've chosen to specialise exclusively in financial services marketing. The regulatory landscape is complex and constantly evolving. Generic marketing agencies can deliver creative work or build websites, but they don't understand the nuances of FCA requirements, the balance between compliance and conversion, or the specific challenges of marketing in regulated sectors.
Our specialisation means:
We understand the regulatory context and can anticipate how requirements will evolve
We've solved these challenges before for banks, building societies, insurers, and fintechs
We can move faster because we're not learning financial services regulations from scratch on your project
We bring insights from across the sector about what works in practice, not just theory
With multi-firm reviews starting throughout 2026, now is the time to ensure your digital presence, brand positioning, and campaign approach are ready for scrutiny.
Three questions to ask yourself:
Could you demonstrate to the FCA that your website helps customers make informed decisions? Not just that it includes the right disclaimers, but that the user experience genuinely supports understanding?
Does your brand positioning demonstrate genuine customer value? Can you evidence how your products and services meet specific customer needs, particularly for vulnerable segments?
Are your campaigns optimised for good outcomes as well as conversions? Do you have evidence that customers understood what they were buying, not just that they bought it?
If you're uncertain about any of these questions, it's worth having a conversation about how your marketing infrastructure stacks up against the new requirements.
Consumer Duty represents a fundamental shift in how financial services brands approach marketing and customer experience. At Creode, we see this as an opportunity to build better digital experiences, create more meaningful brand differentiation, and deliver campaigns that genuinely serve customers whilst driving commercial results.
If you'd like to discuss how your organisation is preparing for the 2026 Consumer Duty requirements, we'd be happy to talk. We're working with financial services brands across retail banking, insurance, wealth management, consumer credit, and fintech to navigate these changes.
Get in touch to start the conversation.
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