Is Your Website Consumer Duty Compliant?

Why digital transparency and accessibility matter more than ever

Let’s be honest, when Consumer Duty first landed, most of us were focused on front-line processes. Call scripts. Sales conversations. Signposting. But as the FCA sharpens its focus, there’s a growing blind spot that could catch dealers and brokers out: your website.

With so many car buyers now starting their journey online, and many applying for finance before they’ve even set foot in a dealership, your digital experience is under just as much scrutiny as your in-person one.

So, here’s the big question: Is your website helping customers make informed, confident finance decisions, or is it quietly letting you down?

✔️ The FCA's spotlight on digital journeys

✔️ What does a good website look like under the duty?

✔️ Common mistakes we're seeing in 2025

✔️ Your digital checklist for 2025

✔️ Your website is your first line of compliance

✔️ Need a finance partner that's compliant and commercial?

The FCA’s Spotlight On Digital Journeys

Under Consumer Duty, it’s not just what you sell that matters, it’s how you present it. That includes:

• Whether your APR is clear and consistent
• How you explain affordability
• What support is offered for vulnerable customers
• Whether users can navigate your site easily, including those using assistive tech

The FCA has made it clear: “tick-box compliance” isn’t enough. If your site gives the impression of transparency but confuses or misleads customers in practice, it’s non-compliant, and could lead to serious consequences.

What Does A Good Website Look Like Under The Duty?

If you're offering online finance quotes, here’s what a compliant, customer-first website should do:

1. Display Representative APR Clearly and Consistently

APR shouldn’t be hidden in footnotes or buried on the final page of a quote journey. It should be:

• Easy to find
• Legible on all devices
• Consistently presented wherever finance is mentioned

This builds trust and meets the FCA’s expectation of fair presentation.

2. Explain Affordability Upfront

Offering a monthly price is helpful, but only if it’s based on something real. Compliant journeys now include:

• Tools for soft credit checks or indicative quotes
• Clear language around “subject to status” and credit approval
• Guidance on what affordability means (not just jargon)

3. Support Vulnerable Visitors

This isn’t just about visible disabilities. The FCA’s 2025 guidance highlights vulnerable circumstances, which could include financial stress, first-time buyers, or mental health challenges.

Websites should:

• Use plain English and avoid overly complex finance terms
• Offer screen reader compatibility
• Allow font resizing, colour contrast toggles, and other basic accessibility tools
• Provide clear signposting to support options

Tip: Try navigating your own site as if you were stressed, confused, or in a rush… that’s often when customers are most vulnerable.

4. Make Contact and Help Easy to Access

The FCA expects firms to make it easy for customers to:

• Ask questions
• Speak to a real person
• Raise concerns or complaints

Live chat, clear contact buttons, and help centre links all contribute to a more compliant and human digital experience.

5. Be Consistent Across Platforms

If your site shows a finance offer, but your email or advert says something different, that’s a red flag.

Under the Duty, customers must get a clear, joined-up experience. Make sure what’s advertised in search or social aligns with the quote journey on your website.

Common Mistakes We’re Seeing In 2025

We’ve reviewed dozens of broker and dealer sites. Here are the top pitfalls:

• “From £179/month” claims with no mention of APR or terms
• Finance tools that generate quotes with no affordability context
• Long, unbroken text that isn’t screen-reader friendly
• No mention of support for vulnerable customers, or it’s hidden in the footer
• Lack of confirmation that credit checks are soft searches (or not stating it at all)

Most of these aren’t malicious, they’re legacy copy or quick wins that haven’t been revisited since the Duty came in.

But in the eyes of the regulator, they matter. And they’re easy to fix if you know what to look for.

✅ Your Digital Checklist For 2025

Here’s a quick list to help brokers and dealers keep their websites in check:

Final Thought: Your Website Is Your First Line Of Compliance

For many customers, your website is your brand. Your first interaction. Your first impression. And, under Consumer Duty, your first chance to prove that you treat customers fairly, from the first click to the final payment.

At Marsh Finance, we work with brokers and dealers every day who are levelling up their digital journeys, not just to comply, but to convert better too.

Because let’s be honest: a website that’s clear, inclusive, and easy to use doesn’t just satisfy the regulator. It builds trust, drives engagement, and helps you close more finance deals.

Need A Finance Partner That’s Compliant And Commercial?

At Marsh Finance, we support our partners with compliant, flexible finance products. We’re always happy to offer practical insight on aligning your digital finance journeys with Consumer Duty expectations.

👉 Partner with Marsh Finance today.