As we approach the second anniversary of the FCA’s Consumer Duty implementation, Complyport hosted a live webinar to discuss how the landscape has evolved, the expectations that now define regulatory best practice, and what firms must do to remain compliant and competitive. Led by Simon Chapman, Senior Director at Complyport, and Hannah Hewitt, Associate Consultant and Consumer Duty specialist, the webinar offered critical insight into how firms should assess and enhance their implementation efforts.
What Is the Consumer Duty?
Introduced by the FCA to raise standards of care for retail consumers, the Consumer Duty addresses long-standing regulatory concerns such as:
- Poor value for money
- Unsuitable product sales
- Inadequate communication
- Weak customer support, especially for vulnerable clients
Since its inception, starting with a discussion paper in 2018 and culminating in final guidance in 2022 the Consumer Duty has evolved from concept to compliance mandate.
Implementation Timeline
- July 2022: Final rules issued
- July 2023: Duty goes live for new and existing products
- July 2024: Duty applies to closed products
- June-July 2025: Firms should be preparing their second annual board report
Two Years On: What the FCA Expects Now
The FCA now expects more than baseline compliance. Firms must actively demonstrate how they are delivering better outcomes for consumers.
- Annual Consumer Duty Board Reports
This is not a tick-box exercise. Your board report should clearly chart your firm’s Consumer Duty journey, highlighting testing, actions taken, and measurable outcomes. The FCA wants to see:
- Evidence of continuous outcomes testing
- Use of robust MI and honest internal challenge
- Improvements based on data and real client feedback
- Fair Value Assessments
These must be updated annually and applied to all new products. Fair value assessments go beyond price, they must consider:
- Absolute and relative value
- Customer experience across the product lifecycle
- Access to support and clarity of communication
- Embedding the Duty into Culture & Governance
Consumer Duty should be a company-wide mindset, not confined to compliance teams or client-facing staff. Key best practices include:
- Cross-functional training
- Senior leadership involvement
- Aligning product development with Consumer Duty principles
Spotlight: Vulnerable Customers
A clear FCA focus in 2025 is how firms are identifying and supporting vulnerable customers.
Key Statistics:
- 17% of UK customers self-identify as vulnerable
- 67% could meet the FCA’s vulnerability criteria (source: NICE)
Firms must adopt a clear, actionable vulnerable client policy. This includes:
- Recognising that vulnerabilities can be temporary or hidden
- Training staff in empathy, grief support, and emotional intelligence
- Avoiding rigid procedures that prevent tailored support
Good Practice Examples
- Partnering with charities like Samaritans to train staff
- Offering a dedicated representative for bereaved or vulnerable clients
- Logging preferences (e.g., best time to call) for personalised engagement
Poor Practice to Avoid
- Requiring repeated documentation (e.g., multiple death certificate requests)
- Relying solely on complaints data without proactive analysis
- Failing to identify and address systemic issues affecting customers
Industry Trends & Insights from Complyport
From our work with a broad range of financial services firms, we have identified three consistent themes:
- Proportionality
Firms with limited retail exposure still have responsibilities under the Duty. The FCA allows for proportionality, but not exemption. All firms must assess how their activities ultimately affect retail customers.
- Policy & Governance Updates
We have supported many firms in updating their compliance manuals to reflect Consumer Duty requirements, including:
- Vulnerable client policies
- Training requirements
- Consumer-focused governance procedures
- Balancing Technology and Human Touch
While AI and automation can improve efficiencies, firms must avoid depersonalised client journeys. Technology should enhance, not replace the human element, especially when dealing with complex or sensitive issues.
Practical Next Steps for Firms
- Do not settle for minimal compliance. View the Duty as an opportunity for competitive differentiation.
- Make Consumer Duty a core part of internal dialogue, especially in product design and governance discussions.
- Use MI and data insightfully. Test assumptions, challenge practices, and show progress.
- Review and refine policies regularly. Update documentation and training materials to keep pace with evolving expectations.
- Access available resources. Complyport offers tools such as:
- A detailed Consumer Duty Checklist
- A practical Consumer Duty Guide
- Our Virtual Compliance Assistant, a free AI-powered research tool
FAQs from the Webinar
Q: Should firms still appoint a Consumer Duty Champion?
A: While not mandatory, many firms continue to appoint a champion, often at board level to maintain focus and challenge.
Q: Can we change the date of our annual board report?
A: Yes, the FCA requires the report to be produced at least annually but does not specify exact dates. However, any delay beyond 12 months should be approached cautiously.
Q: Does upholding a complaint mean we have failed under the Duty?
A: Not necessarily. It depends on the nature of the complaint. Systemic issues are more likely to indicate a failure in Duty obligations.
Q: Is fair value only about offering the lowest price?
A: No. It is about the overall benefit to the customer, not just cost.
Q: Are firms without direct retail clients affected?
A: Yes, if your firm’s actions influence retail outcomes, even indirectly, you are within scope.
Final Thoughts
Consumer Duty is not a one-time initiative; it is an evolving regulatory expectation that demands ongoing action. Firms that fully embrace the Duty will not only maintain compliance but also build stronger, more resilient client relationships.
If you need assistance with implementation, policy reviews, or training, Complyport is here to help. Contact us to learn more or to access our suite of resources designed to support your compliance journey.
