The FCA has published its latest statement of priorities under the Consumer Duty, highlighting how it expects firms to embed the Duty through to 2025/26. The document sets out thematic, multifirm and marketwide workstreams that will shape the regulator’s supervisory and policy agenda.
Consumer Duty remains central to the FCA’s strategy for 2025-2030, aimed at deepening trust, rebalancing risk and improving consumer outcomes in financial services. Rather than layering new prescriptive rules, the FCA emphasises that embedding the Duty effectively across sectors is key to supporting consumers and avoiding unnecessary regulatory burden.
Key Focus Areas
The FCA has identified a number of priority workstreams for 2025/26. These include:
- Embedding the Duty and Raising Standards
The FCA will carry out several crosscutting projects to assess how firms are embedding the Duty. These include:
- Review of products and services outcome – examining how firms design products and services to meet customer needs, including those with characteristics of vulnerability.
- Review of firms’ approaches to outcomes monitoring – assessing how firms monitor and respond to whether they are delivering good customer outcomes. https://www.fca.org.uk/publications/corporate-documents/our-consumer-duty-focus-areas?utm_source=chatgpt.com
- Review of customer journey design – evaluating whether the customer journey includes unnecessary friction or barriers.
- Review of the consumer understanding outcome – how firms’ communications enable consumers to make informed decisions.
- The Duty, Vulnerability and Data Protection
In collaboration with the Information Commissioner’s Office (ICO), the FCA will explore how vulnerability, datasharing and dataprotection obligations intersect. This work is due to begin in Q1 2026.
- Supporting Firms on the Price and Value Outcome
Acknowledging firms’ challenges around assessing “price and value”, the FCA highlights priorities including:
- A market study into “pure protection” insurance, exploring consumer engagement, value and firm behaviour (interim report due by the end of 2025).
- Review of unitlinked pensions and longterm savings, focusing on transparency of charges and value across the value chain (findings expected later in 2025).
- A market study into premiumfinance (for motor and home insurance) to assess fairness and competitiveness.
- SectorSpecific Priorities
The FCA will also focus on specific sectors where risk of harm is greater:
- Retail banking: Assessing fair value in SME business current accounts.
- Consumer finance: Reviewing how consumers understand credit card offers and terms.
- Consumer investments: Identifying vulnerable clients in wealth management, assessing fair value in investment advice, review of complex products (e.g., complex ETPs) and peertopeer platforms.
- Wholesale buyside and sustainable finance: Reviewing model portfolio services and their relationship with the Sustainability Disclosure Requirements (SDR).
Why This Matters
These focus areas reinforce that simply having the Consumer Duty in place is not sufficient. Firms must ensure that it is fully embedded across governance, culture, product design, distribution channels and customer outcomes. There is a clear expectation for firms to use meaningful data and monitoring to demonstrate that they are delivering fair value and good outcomes for all customer groups, including vulnerable customers.
Firms should also note that the FCA intends to publish examples of good and poor practice, setting clearer expectations and enhancing transparency and accountability across the industry.
What Firms Should Consider
- Governance and oversight: Ensure that Board and senior management have appropriate oversight of Consumer Duty embedding, outcome monitoring and datadriven analytics.
- Data and Management Information (MI): Review whether your firm has the necessary management information to monitor outcomes for different customer groups, especially those considered vulnerable.
- Product and service design: Reassess target markets, distribution routes, customer journeys and whether value and support outcomes are being met.
- Customer understanding and support: Verify that communications are clear, customer journeys are not inadvertently disadvantageous (especially for vulnerable consumers), and that support services are robust.
- Value assessment: Undertake rigorous assessments of value, not only price, but benefits, outcomes, distribution costs, costbenefit to customers, and act where value is not being achieved.
How Complyport Can Help
Complyport can support your firm in effectively embedding the Consumer Duty across all business areas by providing:
- Consumer Duty Implementation Support: Assistance in embedding the Duty across governance, culture, product governance and customer outcomes, ensuring alignment with FCA expectations.
- Outcomes Monitoring and MI Frameworks: Design and implementation of data-driven monitoring frameworks to evidence good customer outcomes, including the needs of vulnerable customer groups.
- Price and Value Assessments: Support with designing and documenting fair value assessments, helping you meet regulatory expectations across complex product lines and distribution chains.
- Customer Journey and Communications Review: Evaluation of consumer journeys and firm communications to ensure clarity, accessibility and support for informed decision-making.
- Governance and Oversight Enhancements: Strengthening of governance arrangements, including Board and senior management oversight of Consumer Duty responsibilities.
- Vulnerability Frameworks and Staff Training: Development of tailored vulnerability policies, training programmes and controls.
Contact Us
To explore how these regulatory priorities may affect your business and discuss your Consumer Duty compliance strategy, contact Complyport today to speak with one of our Subject Matter Experts.
Ask ViCA, your Virtual Compliance Assistant – claim your complimentary 20 queries today.
Register here: https://vica.chat
