Across the UK, Europe, and African markets, a new consensus is forming around how digital financial products should be designed for vulnerable and underserved users. The consensus is not new. The people who articulated it first were ignored. Now the industry is catching up.
In the autumn of 2024, a phrase began appearing with striking frequency in the product strategy documents, conference presentations, and investor communications of UK fintech companies. The phrase is “trust-first design,” and it describes an approach to digital financial product architecture that prioritises the construction of user trust through sequenced, low-risk interactions over the rapid accumulation of registered users and early transaction volume.
The movement has been attributed, variously, to consumer research published by the FCA under its Consumer Duty framework, to the publication of the All-Party Parliamentary Group’s 2023 report on financial inclusion technology, and to the post-cost-of-living-crisis reckoning that forced several UK challenger banks to confront the gap between their registration numbers and their active user retention in financially stressed communities.
It has been attributed to all of these things, and it should be. But it was also articulated with precision, specificity, and a framework that would be recognisable to anyone now reading the 2024 product strategy documents by a financial services practitioner based in Nigeria, writing in the context of African digital financial product failures, in 2022 and 2023. At the time, the UK fintech sector was not paying attention. It is worth establishing that record clearly.
In November 2022, Global Finance Review published an analysis of UK fintech expansion strategies into sub-Saharan Africa that drew on the commentary of Adeola Olaniyi, then a frontline financial services practitioner at Zenith Bank PLC in Nigeria. The article made two predictions that were, at the time, considered by most of the UK fintech industry to be either obvious or irrelevant.
The first prediction was that UK fintechs deploying localisation-only product strategies in African markets would encounter a specific and predictable failure: high registration, low sustained engagement, and a deteriorating unit economics profile as the gap between acquired and active users became financially visible. The second prediction was that this failure would stem from a design error: the assumption that digital trust is a default state that users bring to a product, rather than a condition that the product must deliberately construct.
Both predictions have proven accurate. By Q3 2024, at least three major UK fintech firms with disclosed African operations have materially revised their African market strategies in ways that align closely with the failure mode Adeola identified. None of the press releases accompanying these revisions mentioned her analysis. Several of the strategic pivots described are, nonetheless, legibly derived from the framework she proposed.
“I am not interested in attribution for its own sake. What I am interested in is whether the product design ideas that I believed were correct in 2022 are producing better outcomes for users now. If they are, whether or not anyone knows where the ideas came from, that is the outcome that matters. But I do think there is value in the industry acknowledging that the analysis came from practitioners with direct knowledge of the markets being served. Because the next generation of design challenges will also be diagnosed first by those practitioners, and the industry’s habit of ignoring them until the crisis is visible will cost it two more years it does not need to waste.”
Later, the FCA’s Consumer Duty implementation reviews have identified, with remarkable precision, the same three categories of product failure. The FCA’s October 2024 portfolio letter to payment services firms cited inadequate communication in payment failure scenarios, unclear fee disclosure in stress conditions, and the absence of appropriate support pathways for customers in financial difficulty — each one a direct correspondence with the failure modes that Adeola had named few years earlier.
The adoption of trust-first design principles across the UK fintech sector in 2024 has taken several distinct forms. At the product architecture level, a significant number of challenger banks and digital payment platforms have restructured their onboarding flows to front-load positive, low-stakes interactions and to delay the request for deeper financial commitment until a pattern of successful early interactions has been established. The language for this approach varies — trust scaffolding, graduated engagement, progressive commitment architecture — but the underlying design logic is consistent.
At the failure-state design level, the leading digital banks have invested significantly in what some product teams are calling “moment-of-stress UX” — the specific design of product experiences at the point where a payment fails, a balance limit is reached, or a user enters a period of financial difficulty. The design standard that is emerging — proactive notification, plain-language explanation, clear next-step options, and an explicit support pathway — corresponds closely with the framework Adeola described in her 2022 analysis.
At the Africa market level, the strategic revision is more muted publicly but more significant operationally. UK fintechs that have continued their African expansion programmes are, almost universally, doing so with product strategies that now include explicit trust-construction components: zero-cost first interactions, social trust propagation features, and failure recovery protocols that are designed for markets where institutional trust is not a baseline assumption.
“The trust-first design conversation is now mainstream,” she observes. “Which is good. But the next conversation about how trust operates differently in AI-mediated financial services, about what trust means when the product is not a human interface but an algorithm making decisions about a user’s financial life, is not yet mainstream. And it is the conversation that the industry needs to be having now, not in two years when the failure modes are visible.” Adeola advises.
The pattern observable in the trust-first design story: expert practitioner identifies problem and proposes solution; industry ignores practitioner; problem manifests; industry adopts solution under different terminology and with attribution to regulatory guidance; is not unique to fintech. It is a recurring feature of how industries that are dominated by capital and technology narratives relate to practitioners who understand the human and behavioural dimensions of the problems they are trying to solve.
The cost of this pattern — in money wasted on products that failed predictably, in trust eroded in communities that could not afford to have it eroded, in regulatory interventions that were necessary precisely because the industry did not act on available analysis — is real and significant. It does not have to be the permanent mode of operation.
The practitioners who are currently watching the next generation of design challenges develop — in AI-mediated credit decisioning, in digital identity infrastructure, in the embedded finance products being built for gig economy workers and informal sector participants across African and Asian markets — are not waiting to be asked. The analysis is being produced. The question is whether the industry will choose, this time, to engage with it before the failure modes become news.
