Evidencing consumer understanding in protection distribution
Sending documents is not the same as being understood. The Consumer Duty asks firms to check, not assume.
The outcome in brief
The Consumer Duty's consumer understanding outcome requires firms to support customers' understanding so they can make effective, timely and properly informed decisions. The FCA's guidance in FG22/5 is clear that firms should test communications where appropriate and monitor whether customers actually understand what they have been told.
What customers need to understand
For a protection policy, the essentials are what the cover pays out for, how much, for how long, what it does not cover, how much it costs and when payments are taken, how to make a claim, and what support services are included. If the policy replaced an existing one, the customer should also understand what has changed.
Where understanding breaks down
Advice conversations can be long and detailed, and customers often remember the headline rather than the terms. Policy documents are thorough but dense. Insurer branding can be unfamiliar. Small errors, such as a misspelt name or an unexpected premium, can undermine confidence in everything else. None of this is visible unless the firm asks.
Testing understanding after the sale
A short, structured check soon after the policy starts is one of the most direct ways to test understanding. Asking customers to confirm the cover, premium and key details, and whether they know how to claim, gives a recorded answer for each customer. Where answers suggest confusion, the firm can follow up and the customer gets the clarity they need.
Turning responses into evidence
Individual responses show that a particular customer was supported. Aggregated responses show patterns: which products, advisers or lead sources produce more confusion, which questions customers struggle with most, and whether changes to process or wording improve things. That is the kind of outcome monitoring the FCA expects to see in board reports.
Proportionate and practical
Firms do not need to interview every customer. A well-designed digital check, sent to the whole book in the firm's own brand, reaches far more customers than calls alone and creates a clean audit trail. Customers who indicate a need for help, or show characteristics of vulnerability, can be routed to a person.
A note on what our data shows
In one representative Adviser.ai client sample from June to August 2026, about 54 in every 100 completed post-sale checks raised something needing prompt action. Many of those were questions of understanding, such as unexpected details or uncertainty about a replaced policy. Without asking, a firm would have no record that the issue existed, let alone that it had been resolved.
Designing questions that test understanding
Confirmation questions work best when they are specific. Rather than asking whether the customer understands their policy, show them the key details and ask whether they look right. Ask whether they know how to make a claim, and offer a link to the process. Ask whether a replaced policy has been cancelled. Each answer is easy to give and easy to act on.
Vulnerable customers
The FCA's guidance on vulnerable customers expects firms to understand the needs of their customers and to adapt communications where necessary. Offering more than one channel, using plain language, allowing customers to respond in their own time and making a person easy to reach all support understanding for customers who might struggle with dense documents or a long phone call.
Closing the loop
Evidence is strongest when it shows the whole cycle: the customer was asked, raised an issue, the issue was resolved and the customer was told. Recording each step creates a clear audit trail, and reporting on time to resolution shows the firm is acting on what it learns.
Testing communications themselves
Post-sale responses also show which communications work. If many customers say their documents look wrong when they are correct, the documents or the explanation may be confusing. If customers often do not know how to claim, the welcome information may need to be clearer. FG22/5 encourages firms to test communications and improve them based on evidence. Post-sale data provides that evidence at scale, using real customers rather than small test groups.
Getting started
Pick the three or four facts every customer must understand about their cover, ask every new customer to confirm them, and report the results monthly.
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FCA: PRIN 2A, the Consumer Duty
FCA: FG22/5, final guidance on the Consumer Duty
Adviser.ai figures are drawn from anonymised client data and are illustrative. Results vary by firm, product and implementation.
Last updated 27 October 2026