What happened?
Three years after its introduction, industry experts in Insurance Edge reviewed the impact of the FCA’s Consumer Duty. TCC Group CEO Joe Norburn highlighted significant progress in transparency, fair value assessments, and vulnerable customer treatment, with customer outcomes now firmly embedded in strategic planning.
However, substantial variation remains; while leaders use data and behavioural insights to prevent customer harm, laggards still treat the Duty primarily as a documentation exercise.
Why does it matter?
The FCA is increasing its oversight, as evidenced by a rise in Consumer Duty investigations and whistleblowing reports. Proactive general insurance firms must move beyond static compliance frameworks to continuously test and evidence that customer outcomes are consistently positive throughout the product life cycle.
Supporting sources
Frequently asked questions
What has the Consumer Duty achieved in its first three years?
The Duty has improved transparency regarding fee structures, enhanced the focus on fair value assessments, and embedded customer outcomes into corporate governance across the sector.
Why is the FCA increasing scrutiny of Consumer Duty compliance?
The regulator is targeting firms that treat the Duty as a passive paper-based exercise rather than actively using customer data and insights to identify and prevent consumer harm.
- FCA remuneration reform explained: what CP26/27 could mean for firmsAnalysis & Perspectives · September 2, 2026
- IBS Intelligence: Why financial services firms face growing AI governance scrutinyAnalysis & Perspectives · September 2, 2026
- FCA CP26/28: What the AIFM regime reforms mean for wealth managers and firmsRegulatory Horizon · September 2, 2026
- Will Value for Money assessments change how advisers compare pension providers?Regulatory Horizon · September 2, 2026
Reviewed by Joe Norburn, CEO – TCC Group
