Consumer Duty one year on: what the FCA’s findings mean for your firm

What happened?

Consumer Duty moved the regulatory conversation from policy design to demonstrable customer outcomes. The FCA’s early findings make one point clear: having a framework is not enough. Firms need reliable evidence that products, communications, support and pricing work as intended for real customers, including those with characteristics of vulnerability.

Why does it matter?

Boards should be able to follow a clear line from the outcomes the firm wants to deliver to the measures used to monitor them. That means combining management information with customer journeys, complaints, quality assurance, behavioural data and remediation activity. A dashboard of green indicators is weak evidence if thresholds are poorly defined or if it hides material differences between customer groups.

The annual assessment should therefore explain why each measure matters, what action was taken when performance moved outside tolerance, and whether that intervention improved the outcome. Challenge from independent risk and compliance teams should be visible in the record rather than implied.

Who is affected?

Boards, product owners, distributors, operations, risk and compliance teams all need to evidence how products and customer journeys perform, including for customers with characteristics of vulnerability.

Key risks

Product reviews are strongest when they examine foreseeable harm across the full lifecycle. Firms should revisit target markets, distribution assumptions, fair value evidence and the experience of customers who cancel, complain or need additional support. Communications testing should assess understanding, not simply confirm that required words are present.

Actions to take

Where distributors or outsourced providers influence the journey, firms need timely information and clear escalation routes. Gaps in data should trigger proportionate investigation rather than become a standing explanation for limited assurance.

Wider implications

A practical next step is to select a small number of high-risk journeys and test them end to end. Include customer files, call or message records, operational data and the decisions made by frontline teams. Compare the intended outcome with what actually happened, then document ownership and deadlines for improvement.

Recommendations

Consumer Duty should increasingly look like normal business governance: specific outcomes, credible measures, active challenge and prompt correction. Firms that can show this chain of evidence will be better prepared for supervisory questions and better placed to identify harm before it becomes systemic.