For years, “good UX” has been sold to us as one idea: remove friction. Fewer clicks. Faster flows. Shorter forms. One-tap confirmation. And in low-stakes contexts, that usually works.
But agreements, onboarding, credit decisions, client engagement letters, renewals, cancellations, and complaints aren’t low-stakes. They’re high‑consequence moments where speed can quietly sabotage understanding.
That’s why the FCA’s March 2026 consumer understanding review is so interesting. It’s not a generic “make your comms clearer” reminder. It explicitly calls out positive friction: intentional moments in a journey that slow people down on purpose so they’re less likely to make a harmful snap decision.
And it isn’t just a financial services story. The same direction of travel shows up in the legal sector too: the Solicitors Regulation Authority expects client information (including costs and complaint routes) to be provided in a way clients can understand, not buried in paperwork for “compliance theatre”.
The opportunity here is bigger than compliance. “Positive friction” is really a product philosophy shift: design journeys for understanding, not just completion.
What this blog contains
Here’s the paradox: a journey can feel “smooth” and still produce bad outcomes. In fact, some of the smoothest digital journeys are the ones that create the most regret later—because they allow people to glide past the very information that would have changed their decision.
When the FCA talks about consumer understanding, it’s blunt about the goal: customers should have the right information, at the right time, in a way they can understand, so they can make properly informed decisions.
That sounds obvious until you look at how most digital flows are built. Many journeys are optimised to minimise hesitation and keep momentum high—especially near the point of commitment. But “no hesitation” is not the same as “high understanding”.
Positive friction is basically a design permission slip to say: this is a point where we want the customer to pause—because if they don’t pause, what follows is predictable harm: complaints, cancellations, chargebacks, remediation, regulatory exposure, reputational damage, and a customer who feels misled (even if the terms were technically disclosed).
Frictionless UX assumes people will read, process, and weigh information as they move through a journey. But multiple strands of evidence point in the opposite direction: in practice, people routinely skip terms, skim disclosures, and click through agreements—especially when they’re long, complex, or written in language that feels like it’s not meant for them.
The Ofcom has described this as “the T&Cs lie”: asking users “have you read our terms and conditions?” when the realistic answer is “no”. In its own survey research, Ofcom found that between half and two‑thirds of users reported signing up to online platforms without trying to access or read the terms.
In an experimental study of privacy policy and terms-of-service behaviour, researchers found that 74% of participants skipped the privacy policy by selecting the quick join option. (Different context, same behaviour pattern: momentum beats reading.) See the Obar & Oeldorf‑Hirsch study on policy reading behaviour.
And this matters because “non-reading” isn’t neutral. A UK government‑hosted literature review on improving consumer comprehension links insufficient understanding of terms to real downstream problems: consumers reporting issues due to not understanding the terms involved in purchases or services. See the literature review on comprehension of online contractual terms.
So when a business says “but the information was there”, the uncomfortable truth is: in most modern digital journeys, availability of information is not the same as absorption of information.
This is the heart of the FCA’s stance: if you design a journey that predictably encourages skipping, you can’t be surprised when customers don’t understand.
In its consumer understanding review (published 13 March 2026), the FCA frames consumer understanding as an outcome under the Consumer Duty and pushes firms towards an end‑to‑end approach: design, testing, monitoring, governance, and iteration—based on evidence, not assumptions. Read the FCA’s consumer understanding: good practice and areas for improvement.
Inside the practical examples, it defines positive friction clearly: short, purposeful pauses in the journey that help consumers slow down, reflect, and avoid harmful snap decisions.
What’s important is the FCA doesn’t treat “pause points” as theoretical. It points to concrete patterns: calculators, walkthroughs, summaries, short videos, clickable FAQs, and real‑time prompts that prevent common mistakes (including warnings in payment journeys, such as scam alerts).
And it isn’t just about UI components. The FCA is also explicit about evidence: good practice includes using insight from complaints, chat transcripts, analytics, and drop‑off data to identify where customers struggle, then testing changes with real customers to confirm understanding actually improves.
This aligns tightly with the FCA’s Consumer Duty guidance emphasis on “putting yourself in your customers’ shoes”, avoiding communications that exploit information asymmetries or behavioural biases, and testing communications where appropriate—especially when they prompt key decisions and where misunderstanding creates scope for harm. See FG22/5 (Finalised Guidance on the Consumer Duty), Chapter 8.
It also matters that this is not a one-off publication. The FCA’s 2025/26 Consumer Duty focus areas explicitly include a review of customer journey design, with a particular focus on how firms apply friction throughout the journey. See the FCA’s Consumer Duty focus areas (2025/26).
So if you’re writing a blog on this topic, the line is straightforward: friction has moved from being a UX smell to being a regulatory design tool.
To make this blog genuinely useful, you need a clean distinction: not all friction is the same.
The FCA itself has drawn a bright line between friction that protects customers and friction that blocks them. In an Inside FCA podcast transcript discussion of the consumer support outcome, it warns against “sludge” (unreasonable barriers when people try to act in their interests—like making a claim, complaining, or switching), while acknowledging that in the right places friction can be a safeguard against harm (fraud prevention, risk call‑outs, or steps that ensure customers understand the consequences of cancelling). See the FCA podcast transcript (consumer support outcome).
Zooming out beyond the FCA, the UK’s work on online choice architecture (linked to the Competition and Markets Authority) flags practices like pressure selling, hidden charges, and subscription traps—often labelled “dark patterns” or “sludge”—and reinforces that businesses are responsible for being clear, honest, and transparent with consumers. See GOV.UK’s online choice architecture collection.
Internationally, the OECD has proposed a working definition of “dark commercial patterns” as business practices using digital choice architecture that subvert or impair consumer autonomy, decision-making, or choice, and that often deceive, coerce, or manipulate consumers. See the OECD report on dark commercial patterns.
Put simply:
| Type | Example | Outcome |
|---|---|---|
| Negative friction | Hidden fees, confusing forms, “hard to cancel”, long-winded complaints routes | Frustration, drop‑off, poor outcomes, backlash |
| Positive friction | Risk call‑outs, summaries, checkpoints, “are you sure?” confirmations at high‑stakes moments | Better decisions, fewer mistakes, fewer disputes |
There’s also a practical governance point here: regulators increasingly expect you to be able to justify your design choices. The joint position paper from the Information Commissioner's Office and the CMA (via the DRCF) sets out expectations like putting users at the heart of design choices and testing/trialling design so it’s evidence‑based. See the ICO/CMA position paper on harmful design.
If you want a single sentence test: positive friction protects the customer from foreseeable harm; negative friction protects the business from customer choice.
To keep this grounded, here are examples you can lift into your blog as patterns. These aren’t “add friction everywhere” ideas. They’re “put friction where it earns its keep” ideas.
High-stakes commitment screens: add a short checkpoint that forces attention to the material terms (price, renewal, cancellation, exclusions). The FCA’s examples include prompts and warnings that prevent common mistakes and reduce harm.
Layered summaries: lead with a plain-English summary sheet, with detail underneath for those who want to go deeper. The FCA explicitly highlights layered content, visual hierarchy, and placing essential information upfront.
Calculators and walkthroughs: when cost is variable or scenario-based, don’t make people mentally simulate it. Put a simple walkthrough in the journey. The FCA notes calculators and walkthroughs as tools that support understanding (when tested properly).
Now bring in the legal world, because it makes the concept feel “real” fast.
The SRA’s own guidance on client care letters is remarkably blunt: many client care letters are written to satisfy obligations rather than to inform clients in a user‑friendly way, and as a result they can be complicated, too lengthy, and unclear about purpose or what the client needs to do. See the SRA guidance on client care letters.
It also notes that one of the most common complaints to the Legal Ombudsman is lack of clarity around costs—and that being clear on costs at the outset can help prevent complaints.
That is basically “positive friction” in legal clothing: don’t let the engagement letter be a wall of text the client signs to move on. Instead, create deliberate pause points that confirm the client has understood pricing, scope, and complaint routes.
The SRA Code strengthens this: it requires giving clients information in a way they can understand so they can make informed decisions; it also requires providing the best possible information about pricing and likely overall cost at engagement and as matters progress. Link to the SRA Code of Conduct for Solicitors.
So what does this look like in a modern journey?
Cost clarity checkpoint: a short “confirm you understand” step right after cost explanation, not hidden at the end of a PDF.
Scope confirmation: a simple “what’s included / what’s not included” step that clients must actively click through (with plain language, not legalese).
Complaint route visibility: a clear, unavoidable “if things go wrong, here’s how to complain” block at the right time—because the SRA expects clients to be informed in writing about complaint rights and routes.
This is also where a product like
If you want to go deeper without repeating older posts, lean into the “evidence” angle: agreements are increasingly judged not just on what you wrote, but on whether you can show the other person understood. That’s the core idea behind context contracts and informed consent beyond signatures.
There are three reasons this topic is suddenly “now”, not “nice to have”.
First: Consumer Duty has raised the bar from disclosure to outcomes. When the FCA says it wants people to make properly informed decisions and expects testing, monitoring, and governance around understanding, it’s telling firms that “we published the terms” is not the end of the story. FG22/5 is explicit about testing communications where appropriate and acting reasonably to ensure communications equip customers to decide well.
Second: the FCA is explicitly focusing on journey design and friction. Its focus areas for 2025/26 include a review of customer journey design, particularly how firms apply friction across the journey, plus a review of the consumer understanding outcome.
Third: the wider regulatory environment is treating interface design as a consumer protection issue. The UK’s online choice architecture work flags “dark patterns” and “sludge” as harmful design practices (pressure selling, hidden charges, subscription traps), and reinforces that clear, honest, transparent design is a consumer law expectation. Online choice architecture (GOV.UK).
And here’s the human reality behind all of this: the FCA’s own reporting highlights that a meaningful portion of adults lack confidence managing money and have low knowledge about financial matters—so firms are expected to take that into account when designing communications even for mass market products.
On the legal side, the SRA isn’t asking firms to write prettier letters. It is pointing out that clients may not understand or retain information when it’s delivered in dense, legalistic formats, particularly where literacy is low, English is a second language, or clients are in distress. And it links clearer client care communication to reduced complaints and better business outcomes.
This is where internal linking becomes genuinely useful (rather than SEO filler). If you want to connect “positive friction” to outcomes people care about, link it to:
These are not “extra reading”. They’re the logical business case: understanding is a preventative control—and positive friction is one of the most practical ways to deliver it.
I think “positive friction” is going to become a standard design concept in any regulated, high‑dispute environment. Not because regulators want more clicks, but because the old assumption—signature equals understanding—has collapsed in the real world.
The future of agreements isn’t faster signatures. It’s better understanding.
Practically, that means shifting what you measure. Instead of treating drop‑off as the enemy in every scenario, start separating “good drop‑off” from “bad drop‑off”:
Bad drop‑off: people leave because the journey is confusing, tedious, or unfair.
Good drop‑off: people leave because they finally understood something that should have stopped them proceeding in the first place.
And it means being honest about where friction belongs. If you’re adding friction to cancellations, switching, claims, or complaints, you’re drifting into sludge territory—the FCA has repeatedly highlighted that customers shouldn’t face unreasonable barriers when acting in their interests.
But if you’re adding friction at the point of commitment—especially where the customer could be harmed by misunderstanding—then you’re doing what regulators are effectively asking for: building journeys that support informed decisions and can be evidenced through testing, monitoring, and governance.
This is also why I keep coming back to principles rather than “features”. If you want a clean way to frame it, point readers to
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