FCA PRIN 2A.5
For customer communications teams in UK financial services working out what the consumer understanding outcome means for their content. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
The Consumer Duty's consumer understanding outcome, PRIN 2A.5 in the FCA Handbook, describes communications that meet retail customers' information needs, are likely to be understood and support properly informed decisions. It has applied since July 31, 2023.1,2
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the kinds of wording the Consumer Duty's consumer understanding outcome describes, according to the rules and guidance in PRIN 2A.5, and how they tend to show up in customer communications.1
| Phrase or term | In practice |
|---|---|
| Unexplained terms, such as "APR" or "MVR" | Technical terms used without a plain explanation, where the guidance asks for plain, intelligible language. |
| "T&Cs apply" in place of the key fact | Key information that is not prominent or easy to identify, such as a rate change left to the small print. |
| Stacked disclaimers | The guidance lists avoiding unnecessary disclaimers among the ways a firm supports understanding. |
| "Your rate has changed" | Information sent too late for an effective decision, where the rules describe timing before purchase and through the product lifecycle. |
| One message for every customer | Communications not tailored to customer characteristics, including vulnerability, product complexity and the channel used. |
| "Act now" with a low response | A notably lower response rate than expected, which the guidance says suggests the message was not understood. |
| Social posts and promotions | The outcome covers every channel, including social media, and financial promotions as well as post-sale messages. |
Where it goes wrong
One approved claim ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up using the very phrases you are trying to avoid.
"Your fixed rate ends on March 31. Your new rate will be 6.9% unless you choose a new deal."
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
In every channel a firm uses. PRIN 2A.5 covers verbal, visual and written communications in any channel, including social media, before, during and after a sale,1 and we usually find customer-facing wording in:
Mostly by checking understanding, not just reading time. The FCA's March 2026 review of consumer understanding describes good practice as testing with outcomes-focused measures and using the results to adapt communications.3 Keep each tested version as the approved wording, so the version that goes out is the one customers understood.
Ask for every version they publish, in every channel, and check it against what you approved. PRIN 2A.5 asks firms to tell others in the distribution chain about communications that aren't delivering good outcomes.1 Our marketing compliance page shows how teams track this, and US advisers face a similar question under the SEC Marketing Rule.
One record per message saves searching later: the approved wording, the customers it was written for, any testing behind it, who approved it, and every channel and language it went out in. When a response rate drops or the wording changes, that record shows which versions are still live. Related rules are on our financial promotions hub.
How it applies to a specific communication is a question for your legal adviser. Where that communication appears across your markets and languages is a question Arbitr answers.
According to the FCA's policy statement PS22/9, the rules came into force on July 31, 2023 for products and services open to sale or renewal, and on July 31, 2024 for closed products and services.2
They're separate sets of FCA rules that overlap. PRIN 2A.5 says the consumer understanding outcome covers firms producing, approving or distributing financial promotions, as well as sales and post-sale communications.1 The financial promotion rules have their own page.
Its guidance describes presenting information logically, in plain and intelligible language, with key information prominent and easy to identify, without unnecessary disclaimers and with an appropriate level of detail, according to its text.1
No. Arbitr checks content against rules your team has approved, including your legal team's reading of a regulation. What a regulation means for your business stays a question for your legal adviser.
