Can Google Trends help us track Consumer Duty outcomes?
The FCA is on the lookout for imaginative ways to monitor consumer outcomes, so here's our proposal for an early warning system using online search data.
How does the financial services sector track consumer outcomes? It’s a question that’s clearly on the mind of FCA CEO Nikhil Rathi. During the regulator’s Annual Public Meeting, Rathi appealed to the assembled audience, stating that “we will need the help of everyone in the room to keep being imaginative around how we really test the outcomes that consumers are receiving."
Consumer Duty is an outcomes-led regulatory framework. Consumers, according to the FCA’s framework, should expect financial products and services to work as intended; they should deliver a fair price and value; consumers should be able to understand what they are getting into, and firms should support their customers.
There’s also the question of vulnerability. The industry needs to look out for vulnerable customers, which makes it a cross-cutting theme of the Consumer Duty framework.
So how does the FCA tell if Consumer Duty is delivering on its aims? It can request reporting from regulated firms, and it can monitor complaints, but, in the words of Rathi, how can they “really test the outcomes that consumers are receiving”?
Using search as an industry barometer
A 2024 study in Taiwan found that Google searches for symptoms such as fever and cough closely tracked weekly flu-like illness cases in emergency departments, and improved short-term forecasts.
That information came from Google Trends. In simple terms, Google Trends is a tool that shows you information relating to online search terms. Assuming a search term has enough search activity associated with it, you can use Google Trends to see when it peaked in demand.
Here’s what it looks like for the search term ‘World Cup’ since 2004.
The peak (marked at 100) was in 2026, coinciding with this year’s tournament.
Nikhil Rathi’s request for ‘imaginative’ ways to track consumer outcomes got me thinking; surely Google Trends could (or perhaps should) be a part of the mix?
Our Consumer Duty search monitor
Given the potential power of Google Trends for tracking consumer outcomes, we have launched a monthly search monitor (there’s a link at the end of this article).
The monitor is built on around 90 UK search terms, all tracked using Google Trends. Each search term is mapped to one of the four Consumer Duty outcomes, or a separate cross-cutting vulnerability group. The tracker stretches back to 2021, and it compares the latest three months against the same three months last year.
Factoring in the baseline
The tracker uses a market baseline. We benchmark searches for everyday financial products (mortgages, savings, credit cards, etc.) in order to contextualise findings against Consumer Duty outcomes.
Searches for these products are up by 31%, so that’s the lens through which we can view the rest of the findings. This means that the tracker is less about tracking when searches are up, and more about which ones are growing in demand faster than the market baseline.
As an example, searches for terms landing within the ‘price & value’ bucket are up by 63%, compared with the market baseline of 31%. That allows us to calculate how much faster than the market this theme is; 1.63 ÷ 1.31 means that price & value outpaces the market by 24%.
The findings from September 2026
Price & value is growing fastest (+24% vs market)
Some significant movement here (all % show year-on-year):
Loan interest rates +163%
Bank switching offers +140%
Easy access savings +117%
Credit card interest +57%
Fees and charges +58%
All outpace the market, and it’s information that suggests that consumers are actively comparing what credit costs and what their savings can earn.
We also looked at the impact of the UK’s 2022 ‘mini-budget’ and compared it with what is happening in 2026. When the September 2022 mini-budget sent mortgage rates soaring, UK searches for savings rates and standard variable rates hit the highest level in our data, which goes back to late 2021.
This year looks different. Searches for bank switching offers, easy access savings and loan interest rates have all passed their 2022 levels, and the rise has lasted months rather than weeks. Unlike 2022, which saw consumers responding to a single news event, 2026 looks more like a prolonged trend.
Vulnerability is also growing faster than the market (+20% vs market)
The biggest driver is debt and arrears, where searches have more than doubled (+116% on last year):
Credit card debt +66%
Debt consolidation +61%
Mortgage arrears +33%
High-cost credit +54%
Viewed in the context of the cost of living crisis, it’s helpful to see which search terms rise on the back of a news story (like the energy price cap) versus those which stick around for longer:
Searches for ‘cost of living crisis’ are down by about 90% from their peak in August 2022; ‘food bank’ searches are down from a December 2022 peak too, but by 39% and are generally ticking upwards again right now.
Searches for ‘bankruptcy’ are up 133%. Some of that came from a widely reported HMRC petition against a TV pundit in late August, but searches were already rising before the story broke, and searches for debt advice are up too:
There is an as-yet unexplained spike in February 2026, but it’s short-lived and not yet indicative of a wider trend.
Scam checking is at a five-year high
Searches about scams have risen sharply over the last year:
Investment scam +199%
Crypto scam +107%
“Is this a scam” +77%
All outpace the market. It could tell us two things: people are being exposed to scams more frequently, or that people are more aware of the risk and are therefore acting with caution (by carrying out research) before acting.
The second reading is supported by what happened in October 2024, when mandatory reimbursement for authorised push payment (APP) fraud came in. Victims of most bank transfer scams can now get their money back, yet searches kept climbing afterwards. “Is this a scam” has risen steadily for five years and is now at its highest level in our data. That looks less like people reacting to losses and more like people checking first.
Search data can’t tell us which explanation is right, and both are probably true to some degree. But a consumer who checks before paying is exactly the behaviour firms and regulators have been encouraging.
Car finance claim searches have cooled, for now
On the subject of car finance claims and financial redress, car finance compensation searches are down 34%, and claim searches down 23% on the same period last year, having peaked in April.
Something to watch out for is that searches relating to this have come in waves as the redress process has moved on, and the biggest rises followed the FCA’s own announcements. Firms should expect this to happen again when the next update lands and should prepare for it.
Consumer understanding is growing slower than the market (−11%)
Credit literacy searches are up (“what is a credit score” +81%), but retirement decision searches are down 17%, and the overall group dropped in September.
This raises a couple of questions:
Is it a sign that consumers are better informed and, therefore, less likely to search?
Is it a sign that consumers are turning away from Google and towards AI assistants for this type of information?
Consumer support
Complaints searches are up 50%, led by chargeback at +115%.
What this search data can and can’t tell you
This data is clearly only a small piece of a much larger puzzle, but it could be a useful piece for the FCA and regulated firms.
It tells us what people are worried about and what they are looking for online. Search is low friction and therefore a very likely first action for a large cohort of consumers. For that reason, it's a useful early signal.
This data can’t tell us whether firms are delivering good outcomes; it can only give us a clue as to how consumers are feeling now versus how they felt in the past.
What to look out for next month
It will be interesting to see if the drop in ‘consumer understanding’ searches continues. Another theme we’re keen to monitor concerns searches relating to bank branch closures. As things stand, the historic data for this theme is thin and therefore we’ve left it out of the report, but it’s rising and could be one to watch.
View the full Consumer Duty Search Monitor report for September 2026 here.