Consumer Duty requires every stage of the customer journey — including marketing — to deliver good outcomes. Your ads and landing pages must be clearly understandable, fair-value, and designed with vulnerable customers in mind, with evidence you monitor outcomes.
The four outcomes 1. Products and services: ads can only promote products fit for the target market. 2. Price and value: fees and ongoing charges must be surfaceable, not buried. 3. Consumer understanding: plain English, no jargon gatekeeping. 4. Consumer support: post-click experience must match pre-click promise.
What this means for ads - No clickbait or "guaranteed returns" language. - Target market descriptions need to match ad targeting. - Landing pages must match the ad promise precisely (avoids "bait and switch"). - Vulnerable customer flags in CRM should pause generic email sequences.
Evidence requirements Firms should keep records of: target-market definitions, creative review outputs, monitoring data (complaint volumes, conversion to suitable outcomes), and board-level MI.