Evidence that your customers actually understand your communications — persona-based comprehension testing for fund documents, CCI product summaries and client letters.
The Consumer Duty's consumer understanding outcome (PRIN 2A) asks a harder question than any disclosure template: can customers in your target market find, comprehend and act on what you send them? The FCA expects firms to test communications where appropriate and to hold evidence of the results — and the new Consumer Composite Investments regime doubles down on that outcomes-based approach for product summaries.
Traditional consumer research panels deliver that evidence slowly and expensively — weeks of recruitment and fieldwork per document. Most firms therefore test only a handful of flagship documents and hope the rest follow.
From 6 April 2026 the Consumer Composite Investments regime replaces PRIIPs KIDs and UCITS KIIDs with a flexible product summary — and shifts the burden from completing a template to evidencing understanding. Testing every product summary against its target market becomes routine work, not a one-off research project.
Under the Consumer Duty (PRIN 2A), firms must support the consumer understanding outcome and be able to evidence it. The FCA expects firms to test communications where appropriate — particularly for complex products or vulnerable audiences — and to adapt them based on the results.
Consumer Duty testing checks whether real customers in your target market can find, understand and act on your communications — fund documents, product summaries, client letters and financial promotions — and produces evidence of that understanding for the FCA.
Miggins tests each document against a panel of researched consumer personas, including vulnerable customer profiles aligned with FCA FG21/1. Each persona reads the document and answers comprehension probes, surfacing where the target market misreads or misses key information — in minutes rather than the weeks a consumer research panel takes.
Audit-ready reports per document: comprehension scores by persona, misunderstood passages with the reason, readability metrics, and recommended rewrites — the evidence trail Consumer Duty and CCI product summary obligations call for.
Send us a document and we'll show you what your target market understands — and what they don't.
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