Under Consumer Duty, good intentions are no longer enough. Building societies must now prove that their communications genuinely support informed decisions and positive outcomes for every member.

But this regulatory pressure arrives at a time of significant digital transformation. According to the 2025 Building Societies Report, artificial intelligence has emerged as the most prominent technology theme across the sector. Yet for many societies, meaningful investment remains largely at the pilot stage. Concerns around ethics, value and the risk of depersonalising member relationships mean that mobile platforms and apps are currently receiving greater investment priority than AI.

Those concerns speak to something fundamental about the sector. In an industry built on mutual values and close member relationships, the question was never simply "how do we modernise?" but "how do we modernise without losing what makes us different?" And now, regulators are asking a related question of their own: “how do you prove it?”

Engagement is no longer a soft metric

Under the FCA's Consumer Duty framework, which came into force in 2023, the bar for member communications has been fundamentally raised. It is no longer enough for a building society to communicate with its members; it must demonstrate that those communications support informed decisions and positive outcomes. The FCA has been explicit: firms should be monitoring outcomes, rather than relying on traditional engagement proxies like open rates or click-throughs to prove their communications are working.

This is a meaningful shift in expectations. A campaign that generates strong open rates but leaves vulnerable members confused, or fails to reach those without digital access, is not delivering a good outcome (regardless of what the dashboard says). For instance, a high click-through rate on a new savings rate notification is meaningless if a member with a visual impairment can’t navigate the subsequent “Apply” journey using a screen reader. For building societies operating under Consumer Duty, that distinction matters enormously.

Communicating with vulnerable customers begins with clarity

One of the less-discussed implications of Consumer Duty is its impact on how societies identify and support vulnerable customers. The FCA's guidance is clear that vulnerability can be temporary, fluctuating or situational. This means that the same member might need very different levels of support at different points in their relationship with a society.

This challenge makes communication design a frontline vulnerability tool. For example, a standard mortgage renewal letter might have a high open rate, but if a bereaved member can’t find the financial difficulty or bereavement support details within the first two paragraphs, the outcome is a failure.

When correspondence is unclear, overly complex or inaccessible, vulnerable members are disproportionately affected. They are less likely to seek clarification, more likely to disengage and more likely to make decisions that don't serve their interests. Conversely, communications designed with clarity and accessibility at their core create the conditions in which vulnerability can be spotted and addressed (while also reducing the number of complaints).

In practical terms, this means thinking carefully about reading age, plain language, logical structure and alternative formats. It needs to be a design principle built in from the start.

Accessibility as strategy, not compliance

In the UK, one in five adults are deaf, have hearing loss or tinnitus. Two million people have some form of sight loss. Ten percent have dyslexia. Far from edge cases, this represents a substantial proportion of any building society's membership.

Accessible communications (whether print, digital, PDF or in-branch) are sometimes framed as a regulatory obligation. But the more useful framing is strategic: a member who can easily access, understand and act on their correspondence is a more engaged member. And a more engaged member is one whose outcomes a building society can more credibly evidence to the regulator.

The shift in thinking here is from "can we demonstrate compliance?" to "are our members genuinely better served?" The answer to the second question tends to resolve the first.

From campaign metrics to outcome metrics

For many building societies, the measurement infrastructure hasn't kept pace with regulatory expectation. Teams are still reporting on outputs (communications sent, emails opened, responses received), when what Consumer Duty demands is evidence of outcomes. Did the member understand? Did they act in a way that reflects their best interests? Were vulnerable members adequately supported?
Closing this gap requires a change in both mindset and capability. That means consolidating data across communication channels, creating a single view of member interactions and building feedback loops that reveal friction or confusion. These are the building blocks of outcome measurement. They are also, not coincidentally, the building blocks of genuinely personalised, relevant member communications.

The good news is that the same digital investment building societies are already prioritising can deliver both. The key is ensuring that transformation programmes are designed with outcome measurement in mind from the outset, rather than bolted on later.

Evidence is now as important as intent

Building societies have always prided themselves on putting members first. The entire mutual model is built on it. But under Consumer Duty, good intentions aren’t enough. They need to be demonstrable.

There is a significant opportunity for organisations that can really lean into this. Those that get ahead and build communication infrastructures capable of evidencing clarity, accessibility and genuine member understanding will be better placed not just with the regulator, but with their members too.

Trust, after all, is built through consistent experience, not just stated values.

At Paragon, we work with building societies and financial services organisations to design and deliver communications that meet members where they are, across print, digital and hybrid channels. From communication design and data orchestration to member journey strategy and measurable engagement outcomes, we provide the infrastructure and expertise to help societies communicate well and evidence that they're doing so. 

Learn more about driving measurable member outcomes and compliant communications by visiting our Building Societies page here.