It’s been a tough old time for copywriters recently. Massive uncertainty among clients. Shrinking budgets. Unwillingness to commit. Ghosting. And the rising spectre of AI looming over everything.
But there is one area where a lot of professional writing is needed. Consumer Duty. And time is running out for consumer-facing organisations in the UK to implement it.
What it is and why it matters
The Financial Conduct Authority (FCA) Consumer Duty came into force on July 31st 2023. It’s been described as the biggest regulatory upheaval since the FCA was created ten years earlier.
If any financial sector company’s customer communications aren’t clear, straightforward and jargon-free, then they could soon be in trouble with the regulators.
But that’s not all.
They could be in difficulties when it comes to customers too. Existing customers who don’t understand what they’re offering and move their custom elsewhere. And prospects who don’t understand – let alone like – what they see.
Which organisations have to comply with Consumer Duty?
Consumer Duty affects any organisation that deals with consumer-facing financial products like investments, mortgages, pensions or insurance. So we’re talking about banks, building societies, insurers and so forth.
The legislation affects how the products are described, marketed and sold. It also applies to how these organisations sell to, support and communicate with customers and prospects. So it means redrafting all their consumer-facing written communications as well.
Finally, Consumer Duty applies to those who support these organisations. Platform providers, for example. And financial advisers.
An opportunity for financial firms – and for copywriters
Not long before Consumer Duty came in, the FCA published a survey. It found that just 41% of UK adults have confidence in the financial services industry. Ouch.
Many forward-thinking organisations are therefore seeing Consumer Duty not just as an obligation but an opportunity. It will ensure their products and services are truly fit for purpose and that they can serve and support their customers better.
And a rewrite of the whole communications suite is good news, of course, for us copywriters. Ads, brochures, web pages, letters, emails, sales scripts, social media – they all need reviewing and editing at the very least. Some will require a partial or total rewrite.
The FCA have actually warned organisations not to use ChatGPT or other AI tools for this task. What’s needed is skilled, experienced professionals – like us.
Consumer Duty – FCA plans for the future
Implementation has been staggered, with different deadlines for open and closed products (ones already taken out or not open to renewal). The second deadline is due round about now, but many organisations are still way behind schedule.
The FCA has indicated that it’s not planning to come down hard on firms that fall short – for the moment. But that’s likely to change soon.
In the latter part of 2024 and throughout 2025, it will be reviewing how well businesses are complying with the requirements, seeking to identify best practice and to challenge those firms that fall short. Earlier this year they also announced a three-year strategy that includes setting and testing higher standards.
In other words, this is not a do-it-once-and-forget-it scenario. There’s a lot of work out there, and will continue to be so for a long time to come.
The FCA and other regulators and watchdogs are also looking at other consumer-facing sectors. Motor retailers, for example, are already under scrutiny. Mobile phone companies and other telecoms sectors are next, together with energy providers. All will need to take a long hard look at their products, services and communications – and likely expand their copywriting resources.
The effects so far
Many financial organisations have already made big changes of their own. A Royal London survey in July 2024 found that Consumer Duty had made two out of every five financial advisers radically change the way they serviced clients.
Looking at the bigger players, protection and mortgage advice used to be offered as a package. Now it’s being decoupled. This makes everything clearer for consumers. It also means there’s a need for two sets of literature rather than one.
Advisers are becoming careful now to contact their customers more frequently to keep them in the loop about what’s going on. Good news for those customers, at least in terms of clarity and transparency. But also a plus for whoever has to write those extra communications.
Copywriting best practice
Do you have the necessary skills to take advantage of this? Well, you do need a decent amount of financial sector knowhow. And as with most projects these days, the closer you can come to exact experience of the writing required, the better. But guess what? It may involve a rethink and a rewrite, but it’s not something radically different. It’s basically good copywriting practice. Clear, well-structured long copy, in other words.
It may mean you have to ditch the big ideas, of course. And even the small ones. (Although fitting in with a brand’s identity and tone of voice where you can, will still be a part of it.)
So forget the clever wordplay. Or the puns (even current puns are out).
Clarity, simplicity and honesty are where it’s at.
There are guidelines of course – you’ll need to study and follow the FCA recommendations closely. There are also tools you can use – for example, the Flesch-Kincaid calculator to determine overall readability levels. But it’s mostly about using your writing skills to deliver good practice.
And talking of that, writing projects like this is good practice for all your other copywriting projects as well, whatever the sector or audience. Which, in slow times like these, is yet another plus.
For more on financial copywriting and Consumer Duty, or if you’re looking for an experienced financial copywriter, please visit my financial copywriting page
Photo by Steve Johnson on Unsplash