Since implementation of the Consumer Duty, we have seen a flurry of activity from the FCA in conducting product interventions, market and multi-firm reviews, and firm surveys, as well as publishing portfolio and sector letters and examples of good and poor practice, highlighting expectations around Consumer Duty on: Implementation, Price & Value, Annual Board Reports and Complaints and root cause analysis. The regulator has also embarked on a process to simplify the FCA Handbook on retail customer requirements and rid it of over-duplication and complexity.
FCA is clear that this is the beginning of a journey, highlighting a number of areas where it wants to see firms continue to make improvements. It sees consumer protection and economic growth as mutually reinforcing and wants to empower customers by arming them with the right information and support to make good decisions for better outcomes.
As the FCA’s work on the Duty evolves, it will continue with thematic work across sectors, and work on specific products and services. Fair value will continue to be a keen point of focus, but given the holistic application of the Duty, this will inherently include looking at firms’ compliance with the product governance, consumer understanding and customer support requirements.
The Duty builds on, and strengthens, the FCA’s expectations for treatment of vulnerable customers. Meeting the needs of vulnerable customers threads its way through all aspects of the Duty framework. The findings of the FCA’s review of firms’ treatment of vulnerable customers (including older customers) was published on 7 March 2025.
We have created our Consumer Duty Health-check to help firms to stress test their own implementation of the Duty. Please do get in touch if we can support you with this.
