Testing, testing – CCI and the Consumer Duty

Intro

The introduction of the UK Consumer Composite Investments (CCI) framework via PS25/20 represents a step-change in the design and delivery of fund disclosures. Gone are the rigid, regulatory-prescribed formats of old, in favour of a more flexible approach enabling asset managers, insurers and other in-scope product manufacturers to better tailor information delivery to end investors.

While the need to test fund communications under the UK Consumer Duty is not new, this topic has certainly come to the fore in the context of CCI and in-scope firms will need to engage in a consumer testing cycle within their implementation projects to align with the Duty’s principles. A level of focus and urgency is needed to avoid rushed implementation later in 2026.

Confluence^® is actively progressing here to support our clients in their consumer testing requirements, building on our initial design-focused phase for the Product Summary conducted in 2025.

What should testing achieve?

Fundamentally, we’d boil the goals of testing down to three key outcomes:

• Acceptability – Communications should enable consumers to make well-informed investment decisions via a sufficient level of understanding of the features, benefits and risks of a product.
• Accessibility – Creating a technically accessible document is one thing, but ensuring it actually meets the needs of a diverse potential investor base is another thing entirely. Communications need to adequately consider characteristics such as vulnerability.
• Defensibility – Building a sufficient evidence base through testing is critical to demonstrating alignment with the principles of the Consumer Duty – focused on the ‘consumer understanding’ principle.

Testing approaches

Testing approaches will vary depending on the specific use case and outcomes sought. Broadly speaking, testing falls under either a quantitative or qualitative approach, and tests may be used individually or in combination.

Quantitative

Quantitative testing serves as a ‘broader-brush’ approach, aimed at targeting a wider pool of participants (e.g. N = 100+) via concise, online surveys. The intention here is to obtain fast, actionable insights by evaluating strengths and weaknesses in comprehension. Typically, feedback is achieved via a combination of highlighting tools for markup, and direct questions.

Evaluation may assess:

• Stated and revealed understanding
• What stands out and engages the reader
• The navigability of the disclosure format
• Likes, dislikes and preferences
• Awareness and understanding of risk
• Intended actions based on the information supplied – linking insights with actions and outcomes

Testing might focus on a single Product Summary example, or it might involve applying an A:B testing approach comparing two documents, for example two versions of the same Product Summary.

This form of testing is intended to provide a directional understanding of communication performance against key evaluation criteria, with scoring and evidential reporting.

Qualitative

Qualitative testing involves a more in-depth approach, typically conducted via lengthier 1:1 interviews and/or digital panels with a smaller pool of participants. While the evaluation criteria above are all relevant, this approach offers an opportunity to solicit deeper insights and diagnostics on consumer understanding.

This form of testing may be more appropriate where multiple communications need to be tested as part of a consumer journey, or to reflect a range of nuances in a single communication type. For example, firms might wish to test sample narratives and communication approaches in more depth across different fund ranges, each with their own characteristics.

Equally, this more detailed form of testing might involve creating tasks for participants to complete to evaluate their success in navigating, understanding, and taking action based on the information communicated.

From an outcomes perspective, this will garner greater depth in diagnostics and recommendations, with more bespoke reporting and evidencing across a range of communications.

How Confluence can help

Confluence is actively engaged with a leading independent UK provider of consumer testing support to the investment industry, rooted in the Consumer Duty’s principles.

Via this engagement, we will build upon our extensive Product Summary design initiative conducted in 2025 to support our clients in a CCI-specific consumer testing cycle, launching early Q2. By bringing our clients together with a testing provider in a joined-up fashion, we will collectively make better progress to deliver good outcomes.

Based on the above testing approaches outlined, Confluence will undertake:

Quantitative testing – running our CCI Product Summary baseline template through a broader online testing phase. This will utilise ‘crowdsourced’ representative narrative with the focus on testing how our proposed design aids consumer understanding and building on key principles embedded within our design approach including ‘key information up front’, accessibility and flow/pacing of information.

Qualitative testing – building on the above, Confluence will support clients on a 1:1 basis in more bespoke, in-depth testing. This provides an opportunity to test client-specific narratives in the context of Confluence’s Product Summary template or a fully bespoke design where required. This may involve multiple variants to account for a range of fund types, each with their own characteristics.

Testing through Q2 2026 will deliver evidence-based outputs to support our clients, and enable iteration where required towards a final position, ready for end-to-end testing from Q3 onwards.

If you’d benefit from support in your consumer testing journey, please get in touch with your Confluence representative to discuss further.