Customer Journey

What the FCA wants to understand

The FCA wants a clear picture of the experience a customer will have when interacting with your business, from their first contact through to ongoing servicing and renewal.

This section should explain how customers are acquired, how their needs are assessed, how products are recommended or arranged and what support they receive after the sale. The FCA specifically expects firms to describe the end-to-end customer journey, including how new clients are obtained, how customer relationships are managed and what after-sales support is provided.

The regulator is looking for evidence that you have considered the entire customer lifecycle rather than focusing solely on the point of sale. It should be able to understand not only what happens at each stage, but also how those processes support good customer outcomes and align with Consumer Duty.

The customer journey is where your business model, customer proposition and Consumer Duty commitments come together in practice.

A well-considered customer journey demonstrates that you understand how customers interact with your business and have designed processes that support their needs throughout the relationship. It also helps the FCA assess whether customers are likely to receive consistent service, appropriate support and good outcomes at every stage of their experience.

The strongest applications show that the customer journey has been designed around the customer rather than around internal processes. They explain not only what happens, but why those steps exist and how they help customers make informed decisions.

What good looks like

Strong applications typically demonstrate:

How customers first become aware of and engage with the business.
The process for gathering customer information and understanding needs.
How products, insurers or services are selected and recommended.
How decisions and recommendations are communicated.
What support customers receive throughout the policy lifecycle.
How claims support, policy changes and renewals are managed.
How vulnerable customers are identified and supported during the journey.
How customer feedback and service outcomes are used to improve processes.

The FCA should be able to follow the customer experience from initial enquiry through to renewal without needing to make assumptions about how the business operates.

Example Approach

“Customers will primarily be acquired through referrals, professional relationships, networking activity and digital marketing. Following an initial enquiry, a fact-finding process will be undertaken to understand the customer’s needs, objectives and insurance requirements. Suitable insurers and products will then be identified and discussed with the customer before recommendations are made. Once cover is arranged, customers will receive ongoing support throughout the policy term, including assistance with claims, mid-term adjustments and periodic reviews where appropriate. Renewal discussions will be undertaken in advance of policy expiry to ensure cover remains appropriate for the customer’s needs. Customer feedback, complaints and service outcomes will be reviewed regularly to support continuous improvement and deliver good customer outcomes.”