FCA Consumer Duty and Insurance Translation

Quick answer — The Consumer Duty sets no translation requirement. It sets a comprehension requirement — firms must support and evidence customer understanding — and where a book includes customers who read English poorly, that is difficult to demonstrate in English alone.

Vitra.ai Universe produces the evidence trail as a by-product of the work.

A comprehension standard, not a disclosure one

The FCA's Consumer Duty has applied to open products since July 2023 and to closed books since July 2024. Of its four outcomes, the one that reaches language is consumer understanding: communications must be clear, fair and not misleading, and firms have to support understanding and be able to show they did. Handing someone an accurate document is not the same as evidencing that they understood it. That gap is the whole of the language question in the UK.

Nothing in the Duty names a language. That is precisely why it bites.

Insurance is squarely in scope

General insurance, protection and distribution all sit inside the perimeter, and the Duty travels down the distribution chain. A broker or MGA carries it too, which means a translated wording has to survive being explained by somebody who did not write it.

What the evidence looks like

The middle row is the one firms skip: if you cannot split complaints data by the customer's language, you cannot evidence the outcome for that group, and the Duty asks about groups.

The IPID survived Brexit

The insurance product information document remains a UK requirement, and it is already a comprehension artefact — short, standardised, written to be understood. Translating it well is a cheap first move. Document translation keeps its structure intact, which matters because the IPID's layout is part of the regulation.

Where it usually fails

The sale happens in Polish or Punjabi and the claim happens in English.

That is a support-outcome failure rather than a translation failure, and it is the most common one in UK retail books. Motor and travel see it first, because both are bought quickly and claimed under stress — motor and travel each have their own version of it, and liability has the slow one.

Where to start

The IPID and the claims journey, in your two largest non-English customer languages.

Run both through quality control with back-translation on, because the review record is the evidence. Policy wording translation comes next, and the wider capability map is in AI for insurance.

Elsewhere: the US, Canada, the Gulf, Southeast Asia.

FAQ

Does the FCA Consumer Duty require translation? No. It requires firms to support and evidence customer understanding, which is a comprehension standard rather than a translation one. Where a book includes customers who read English poorly, that is hard to demonstrate in English alone.

Which Consumer Duty outcome affects language? Consumer understanding, mainly, and consumer support behind it. Communications must be clear, fair and not misleading and firms must show they helped customers understand, then keep support at the same standard as the sale.

Do brokers carry the Duty as well as insurers? Yes. It travels down the distribution chain, so a broker or managing general agent carries it too. A translated wording therefore has to survive being explained by somebody who did not write it.

Does the UK still require an insurance product information document? Yes, the IPID remains a UK requirement after Brexit. It is already built to be understood, short and standardised, which makes translating it well the cheapest first move towards the understanding outcome.