Why firms need to prove customer outcomes not just report them
On the 7th July 2026, the FCA announced that
14/08/26
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Customer journeys and vulnerability lessons from the FCA’s basic bank account review
On the 7th July 2026, the FCA announced that nine of the UK’s largest banks and building societies had committed to improving how they offer basic bank accounts following a mystery shopping exercise. Basic bank accounts are designed to support people who may not be able to access standard current accounts, providing essential banking services without fees or overdraft facilities.
The regulator’s findings highlighted some important concerns. The FCA identified widespread instances where customers who should have been able to access essential banking services were at risk of being excluded altogether.
Across 298 mystery shopping interactions, around a third were rated poor or very poor. Customers who may have benefited from a basic bank account were not always informed that the product existed, while some vulnerable customers were directed towards online application journeys that were unsuitable for their circumstances. The FCA identified particular challenges for customers experiencing financial hardship, those without standard forms of identification and individuals with no fixed address.
This review highlights that although these banking services exist, the customers they are intended for may be unable to complete a successful customer journey to access them in some circumstances.
This matters under the Consumer Duty in particular, as it is not simply about product availability. It is about whether products, communications, processes and people work together to deliver good outcomes in practice. If customers cannot find the right product, understand their options, or complete a journey that meets their needs, intended outcomes can be quickly lost.
Financial inclusion and accountability
Underlying the FCA’s review is a broader financial inclusion objective. Basic bank accounts are intended to provide access to essential banking services for customers who may otherwise struggle to participate fully in economic life.
The FCA’s response also highlights the importance of accountability. Firms are expected to identify issues, monitor outcomes, evidence improvements and demonstrate that responsibility for customer access and support is clearly owned.
The banks involved have committed to improving customer outcomes and the regulator has made clear that it expects progress to be demonstrated in practice.
Customer journeys are where outcomes succeed or fail
One of the most important aspects of the FCA’s findings is that they relate to one of the simplest banking products available. Basic bank accounts are not complex propositions, yet the mystery shopping exercise still identified significant weaknesses in how customers were guided towards suitable outcomes.
The review reinforces the importance of testing customer journeys in practice rather than assuming intended outcomes are being delivered. Mystery shopping, customer testing and outcome monitoring can often reveal barriers that may not be visible through governance reviews alone.
That lesson applies beyond retail banking. A product may be suitable, communications technically compliant and governance robust. But if customers face friction during the journey, outcomes can still suffer.
Firms should therefore heed the FCA’s message that understanding how customers access products matters just as much as reviewing the products themselves.
Why vulnerability is central to the discussion
The review also demonstrates the close relationship between vulnerability and customer journey design. The mystery shopping exercise focused on customers experiencing financial hardship, previous bankruptcy and difficulties providing standard forms of identification. These are the kinds of circumstances that can make engaging with financial services more difficult, even when appropriate products are available.
Most firms now have some form of vulnerability framework in place but recognising that a customer may need additional support is only one part of the challenge. The most important question is how firms respond once they recognise that a customer may need additional support.
For example, a customer with no fixed address may not require a different product – they may simply need a different route through the onboarding process or a customer facing financial hardship may need additional guidance to understand their options. Viewed through that lens, vulnerability becomes as much a journey issue as a customer issue. The objective is not simply identifying vulnerable characteristics but ensuring the process remains accessible when those characteristics are present.
Staff capability still matters
The findings also underline the importance of frontline expertise. At a basic level, it’s critical that customer-facing staff understand the products available, who they are designed for and when they may be appropriate. If staff do not recognise when a customer could benefit from a basic bank account, the customer journey can break down at the first interaction.
This is why training should not be viewed as a standalone compliance requirement. Product governance, customer communications, vulnerability frameworks and staff capability all contribute to the same outcome. Weakness in any one area can create unnecessary friction for customers.
A wider message for financial services firms
Just days before this announcement, the FCA proposed reforms to simplify investment disclosures, emphasising clearer communications and the use of plain English.
The regulator noted that only 6% of the investment disclosure documents it reviewed for readability were written in plain English. Although addressing different issues, both initiatives reflect the FCA’s growing focus on what customers actually experience in practice, rather than what firms intend them to experience.
Whether the issue is opening a bank account or understanding investment charges, the underlying question is the same: can customers understand their options and reach a good outcome?
For firms, that means looking beyond individual products and considering the entire end-to-end customer journey.
At TCC, we help firms deliver effective compliance that connects regulatory expectations, operational reality and customer outcomes.
The FCA’s basic bank account review is a useful reminder that good customer outcomes are rarely determined by products alone. They are shaped by the quality of the journeys surrounding them, the effectiveness of communications and the ability of firms to recognise and respond to customer needs at the moments that matter most.
Get in touch today to discuss how we can help your firm.