Implementing the new FCA consumer duty

The third deadline in the FCA’s Consumer Duty implementation timeline has passed and the Consumer Duty is now in force for new and existing products and services that are open to sale or renewal. Firms still have until 31 July 2024 for the implementation of the Duty for closed products and services.

This means that Firms should now have a detailed implementation framework to meet the FCA’s higher standards for consumer protection. You can find a helpful checklist in our July 2023 Consumer Duty View of key steps we recommend Firms to have undertaken in meeting the implementation deadline.

We know you’re keen to understand how the FCA’s higher expectations for the standard of care and continuous improvement will translate into practical steps you need to take in the future in order to be compliant with the Consumer Duty. Read our November 2023 Consumer Duty View to find out more about post-implementation “Day 2” actions.

So, we’re here to help you demystify it.

FCA consumer duty implementation: how we can help

We’ve been working with clients right from the start of the Consumer Duty timeline to develop implementation strategies, as well as liaising with the FCA and various industry bodies to understand the ‘real life’ implementation. We been engaged in the detailed implementation of consumer duty with a number of leading Financial Institutions, Asset Management and Investment Funds, Banks, Wealth Managers, FinTechs and Insurance clients.

We have custom-built a range of documents and services to support implementation, efficiently and cost effectively, no matter what stage of implementation you are at. These items are based on extensive work we have done with multiple industry clients since Q3 2022 and represent market leading thinking and practical execution.

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Implementation timeline

The implementation timeline has been confirmed as:

31 October 2022
Boards (or equivalent management body) to have agreed implementation plans; evidence scrutiny, challenge and robustness.

30 April 2023
Manufacturers to complete reviews for existing open products and services and share information with distributors (where appropriate for outcomes).

31 July 2023
New effective date for in scope new and existing products and services that are open to sale or renewal.

31 July 2024
New effective date for closed products and services.

For details on the final Consumer Duty rules and guidance, read our latest edition of Consumer Duty View here.