What happened?
The FCA’s Consumer Duty introduces higher standards of care across the entire customer lifecycle, replacing the previous ‘Treating Customers Fairly’ (TCF) requirements. This transition poses complex operational and cultural shifts for regulated firms.
Writing in FT Adviser, TCC Associate Director Neil Dethick identifies four critical operational complications that businesses should address to prevent implementation delays and ensure compliance.
Why does it matter?
Unlike previous regimes, the Consumer Duty requires proactive evidence of good outcomes across products, pricing, comprehension, and customer support. Moving beyond simple disclosure to active monitoring and vulnerability tracking presents significant system and data integration hurdles for traditional compliance operations.
Supporting sources
Frequently asked questions
How does the Consumer Duty differ from Treating Customers Fairly?
The Consumer Duty is a much more demanding standard, requiring proactive, data-led evidence that clients are receiving fair value and good outcomes, rather than just proof of fair procedures.
What are the common operational challenges in implementing the Duty?
Firms typically struggle with data collection, tracking customer comprehension, integrating vulnerability metrics, and establishing continuous, end-to-end customer journey monitoring.
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- BankingTCC helps retail banks, challenger banks, building societies and specialist banking providers strengthen governance, manage financial crime risk and demonstrate good customer outcomes. Our specialists support Consumer Duty, remediation, regulatory transformation, FCA intervention and compliance assurance programmes through advisory, managed services, specialist resourcing and technology-enabled compliance. With more than 25 years of experience supporting FCA-regulated firms, we help banks respond confidently to regulatory scrutiny while strengthening operational resilience and customer trust.
- General Insurance & ProtectionTCC helps insurers, brokers, MGAs and protection providers evidence fair value, strengthen customer outcomes and identify emerging customer harm. We assess product governance, claims performance, distribution oversight and vulnerability risks, helping firms create regulator-ready evidence, improve operational performance and demonstrate that products and services deliver value throughout the customer lifecycle.
- Lending & Consumer CreditTCC helps consumer credit firms evidence good outcomes, strengthen affordability and vulnerability frameworks, and manage complaints, remediation and regulatory risk. We support lenders with practical, regulator-ready compliance programmes that improve governance, customer treatment and operational resilience.
- Wealth Management & Financial AdviceTCC helps wealth managers, financial advisers, networks, platforms and consolidators strengthen compliance, evidence customer outcomes and manage regulatory risk. Every engagement is designed to deliver practical improvements, stronger governance and regulator-ready evidence. For more than 25 years, we have helped FCA-regulated firms navigate regulatory change, supervisory reviews and business growth.