Amplifi and CUE unite AI analysis with consumer testing for FCA duty

A new partnership targets the FCA's Consumer Duty intelligibility gap, combining AI document analysis with live consumer testing at scale.

By Disrupts Editorial Team Mon, 2 November 2026 AI level 2 of 5

AI level 2 of 5: drafted by our AI editorial assistant from the company's announcement; fact-checked, edited and signed off by Mark Walker, Editorial Director. What the levels mean

A modern conference room with a large oval wooden table and light grey chairs faces a wall-mounted screen displaying a data dashboard, illuminated by bright natural light from tall windows overlooking a city.

Amplifi, an AI-powered intelligibility platform developed alongside the FCA, and CUE (Customer Understanding Exchange), a specialist consumer testing firm, have announced a partnership designed to help investment firms demonstrate compliance with the FCA's Consumer Duty obligations. The tie-up arrives at a moment when the regulator is intensifying scrutiny of how effectively financial firms communicate with customers, and as the broader industry grapples with the gap between providing information and proving it is understood.

The stakes are considerable. In a recent FCA review of pre-sale investment disclosures, every one of the 172 documents assessed using Amplifi's intelligibility platform fell below the regulator's benchmark for customer understanding. That is not a statistical outlier; it is a sector-wide signal that compliance teams have been treating disclosure as a documentation exercise rather than a communications one.

AI flags the risk; humans test the fix

The commercial logic of the partnership is straightforward. Amplifi's platform can scan an entire portfolio of customer-facing documents, assign each one a regulator-recognised intelligibility score, and rank them by risk. CUE then focuses its live consumer testing and expert remediation on the documents that score most poorly, creating a documented evidence trail that firms can present to the FCA as proof of improvement.

Minesh Patel, CEO of Amplifi, framed the arrangement in terms of complementary specialism: "CUE's sector depth in investment is exactly the complement our intelligibility score needs to make a real difference for firms and their customers."

CUE co-founder Zak de Mariveles was direct about what Consumer Duty has changed for the industry: "It's no longer enough to assume that providing information means customers will understand it. Firms need to identify where understanding may break down, test that understanding and demonstrate what they've done to improve it."

Both firms retain independent client relationships and new-business pipelines. The partnership strengthens two separate offers rather than merging them, which limits integration risk and preserves each firm's regulatory standing as an independent adviser.

The wider convergence: RegTech meets behavioural testing

The Amplifi-CUE model is a small but instructive illustration of a larger convergence reshaping financial services compliance. Regulatory technology (RegTech) has, until recently, focused predominantly on transaction monitoring, fraud detection, and reporting automation. Consumer Duty shifts the lens toward outcomes, demanding that firms evidence not just what they sent to customers but what customers actually understood. That requires a different toolkit, one that blends natural-language AI with the kind of qualitative, human-in-the-loop testing that behavioural science firms have historically supplied to product designers rather than compliance officers.

For investors tracking the RegTech space, that convergence opens a distinct category: AI-plus-human intelligibility platforms operating at the intersection of compliance, communications, and consumer psychology. The FCA's Consumer Duty framework, which came into force for closed-book products in 2024, has already prompted significant spend on evidence generation. If the 172-document finding from the Amplifi review is representative of the broader market, the remediation pipeline for UK investment firms alone is substantial.

The macro read-across extends beyond the UK. The EU's PRIIPs and MiFID II frameworks impose broadly similar obligations on investment product disclosures, and the SEC has been sharpening its own plain-language requirements for retail-facing documents. A compliance toolchain that satisfies FCA audit requirements and can be adapted to EU or US regulatory benchmarks carries a geographic expansion story that goes well beyond structured products. That international optionality may prove to be the most strategically significant dimension of today's announcement, even if neither firm has articulated it publicly yet.